The law
CGST Rules 2017, Rule 86A(1)
Commissioner or authorised officer (not below Assistant Commissioner) may disallow debit of credit, for reasons recorded in writing, where supplier non-existent, goods not received, tax not paid, recipient non-existent or no valid documentSource
CBIC guidelines on Rule 86A (2 November 2021)
Limits: up to ₹1 crore AC or DC, ₹1 to 5 crore Additional or Joint Commissioner, above ₹5 crore Commissioner; reasons on material evidence, not suspicion; not mechanical; amount blocked not more than suspected credit; taxpayer can submit evidence for reviewSource
CGST Rules 2017, Rule 86A(2)
Officer may allow the debit on being satisfied that conditions no longer exist, fully or partlySource
CGST Rules 2017, Rule 86A(3)
Block ceases one year from the date imposed; NZS Traders (Bombay HC, 25 March 2026) held it lapses by operation of law even if registration is cancelledSource
Hemang Bipin Varaiya v State of Maharashtra (Bombay HC, 2026)
Negative blocking beyond the balance available in the ledger is not allowedSource
Rithwik Projects v UOI (Bombay HC, 1 October 2025)
Block without recorded reasons set aside; timely post-decisional hearing neededSource
Tvl Nualco v AC (Madras HC, 28 August 2026)
Blocked credit cannot be used for the 10 percent appeal pre-deposit while the block stands; unblocking request to be decided by speaking orderSource
Government fee
No fee for a representation. Source: https://cbic-gst.gov.in/pdf/guidelines-rule-86A.pdf