GST
First steps when credit ledger is suddenly blocked
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Facts
Your ITC has most likely been blocked under Rule 86A, which lets an officer stop you from using part of the credit. The block does not take the credit away, but you cannot use it to pay tax until it is lifted or one year passes.
Provisions and law
- Rule 86A(1), CGST Rules 2017Commissioner or authorised officer, not below Assistant Commissioner, may disallow debit of ITC for recorded reasons where the supplier or recipient is non-existent, goods were not received, tax was not paid or there is no valid document
- CBIC guidelines on Rule 86A, 2 November 2021Block must rest on material evidence, not suspicion; amount not more than the suspect credit; monetary limits for officer ranks; taxpayer may give evidence for review
Analysis
Rule 86A(1) allows a block only for recorded reasons, and the CBIC guidelines say it must rest on material evidence. Start by noting the date, amount by tax head and officer name shown on the ledger, because the one-year clock and the officer's power both depend on these. Example: ₹6,40,000 blocked on 12 August 2026 means the block lapses on 12 August 2027 unless lifted earlier. Meanwhile your GSTR-3B is still due, so plan to pay output tax in cash.
Conclusion
- Open Services, Ledgers, Electronic Credit Ledger and download the blocked credit details.
- Note the blocking date, amount by head and officer name.
- Check View Notices and Orders for any related notice.
- Write to the officer asking for the recorded reasons and a hearing.
- Arrange cash for this month's GSTR-3B so returns stay on time.
Do not stop filing returns because credit is blocked; late returns add late fee and interest.
A Savvy can do this for you
Credit ledger blocked under Rule 86A: representation and unblocking
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