Answer

GST

Preparing for the Rule 86A hearing

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  1. Facts

    Carry invoice-wise evidence of genuine purchases and payment, and a short written note. Ask for a written order after the hearing.

  2. Provisions and law

    • Rule 86A(2), CGST Rules 2017The officer may allow the debit, fully or partly, once satisfied that the conditions no longer exist
    • 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
  3. Analysis

    The CBIC guidelines expect the officer to review your evidence. A clear two-page note works better than a stack of papers: what was blocked, which suppliers, and why each purchase was genuine. Example: show that goods from the supplier went into production, with stock records and sales of the finished goods. Ask for the hearing to be recorded and for a speaking order.

  4. Conclusion

    1. Prepare a two-page summary note with a table of invoices.
    2. Bring copies of invoices, e-way bills, transport and bank proofs.
    3. Bring an authorisation letter if a CA or staff attends.
    4. Ask that your submissions be recorded.
    5. Request a written, reasoned order.

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