Answer

1. F

   Facts

   No. Rule 86A needs an officer not below Assistant Commissioner. The CBIC guidelines set higher ranks for larger amounts.

2. P

   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
3. A

   Analysis

   Under the CBIC guidelines of 2 November 2021, up to ₹1 crore can be blocked by an Assistant or Deputy Commissioner, ₹1 crore to ₹5 crore by an Additional or Joint Commissioner, and above ₹5 crore by the Commissioner. A ₹2 crore block by a Superintendent is outside the rule. Point this out in your representation; if the block stays, it is a strong ground in a writ petition.

4. C

   Conclusion

   1. 1Check the officer's designation on the portal block details.
   2. 2Compare it with the monetary limits in the CBIC guidelines.
   3. 3Raise the lack of authority in writing with the jurisdictional Commissioner.
   4. 4Ask for the block to be withdrawn.
   5. 5Keep this point ready for a writ petition if needed.

General guidance from TaxSavvy’s library of money processes. Laws change; your Savvy confirms the answer on your exact case before anything is filed.