Compliance Pack

Credit ledger blocked under Rule 86A: representation and unblocking

  • Rule 86A lets an officer freeze part of your input tax credit if he believes it came from a fake or unpaid supplier.
  • Deadline: As soon as the block appears; the block lapses by law one year after it was imposed
  • Done in Representation filed within 5 working days of complete documents
  • Prepared by your Savvy, checked by a CA
  1. Ledger screenshot showing blocked amount
  2. When was the block imposed
  3. Download ledger and blocked credit details
  4. Representation copy with acknowledgement

Answer in brief

Rule 86A lets an officer freeze part of your input tax credit if he believes it came from a fake or unpaid supplier. We find out the amount and reason, check whether the block is lawful, file a representation with proof that your purchases were genuine, and push for unblocking or, if needed, a High Court petition.

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From the official sources

What the law says, and what trips people up

From the official portal's manuals and FAQs, with the source for each point.

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

On the portal

  1. Login at gst.gov.in > Services > Ledgers > Electronic Credit Ledger; view balance and blocked credit details
  2. Note the blocking date, amount by head and the officer's name shown on the portal
  3. Check Services > User Services > View Notices and Orders for any related notice
  4. Submit the representation to the jurisdictional officer by email and in person; keep acknowledgement

What trips people up

  • Credit blocked with no notice or reasons

    Ask for recorded reasons; courts have set aside blocks without reasons and required a timely post-decisional hearingSource

  • Ledger shows a negative balance after blocking

    Negative blocking beyond available balance is not allowed; seek removalSource

  • Block still showing after one year

    It ceases by law after one year; ask the officer to update the ledger, cite NZS TradersSource

  • Wanted to pay appeal pre-deposit from blocked credit

    Not allowed while the block stands; pay in cash or get the block lifted firstSource

  • Officer blocked more than the suspected credit

    Guidelines say the block must not exceed the credit believed ineligible; ask for proportionate unblockingSource

People ask

How long can my credit stay blocked?

No more than one year from the date it was imposed.Source

Who can block my credit?

The Commissioner or an officer not below Assistant Commissioner, with higher ranks for larger amounts.Source

Can I get part of it released?

Yes. The officer can allow debit fully or partly on your evidence.Source

Is there an appeal against Rule 86A?

No separate appeal form; taxpayers make a representation and, if needed, file a writ petition in the High Court.Source

Can the officer block credit I do not have?

No. High Courts have held negative blocking illegal.Source

IDFD

How we solve it: 4 steps

Every line tracked live.

Step 1 of 4 · What we need from you

Tap each one you already have

Ready0 / 7
  • Ledger screenshot showing blocked amount
  • Names of suppliers behind the block
  • Invoices, e-way bills, transport proof
  • Bank payments to those suppliers
  • Stock and production records
  • Ledger balance on block date
  • Any notice or summons receivedOptional

Connect now

A Savvy replies in minutes.

Fixed price before you pay. Your Savvy is paid only after you accept the work.

Pay and start

₹4,999

₹4,999 + ₹899.82 GST = ₹5,898.82

As needed. Delivered in Representation filed within 5 working days of complete documents. Due: As soon as the block appears; the block lapses by law one year after it was imposed

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