SPL Steel Processors Private Limited Vs Commissioner of Revenue (Calcutta High Court)
Summary: The writ petition was filed by SPL Steel Processors Private Limited challenging, inter alia, the action of the GST authorities in blocking its Electronic Credit Ledger for Financial Years 2021-22, 2022-23 and 2023-24 in respect of the tax period from 01.02.2026 to 17.06.2026. The petitioner challenged the GST Authority’s order dated 15.06.2026 whereby Rs.4,43,53,116/- was blocked in its Electronic Credit Ledger under Rule 86A of the CGST/WBGST Rules, 2017, alleging, inter alia, that the supplier was non-existent.
The petitioner submitted that all purchases were genuine and supported by documents and contended that blocking the Electronic Credit Ledger was arbitrary, illegal and unsustainable. After receiving the blocking order, the petitioner communicated by e-mail on 20.06.2026 seeking review and unblocking of the ITC and requested an opportunity of hearing to explain the transactions. The petitioner stated that it had been debarred from filing returns and discharging statutory obligations in a time-bound manner, causing grave financial and operational difficulties.
The GST authorities subsequently issued a notice under Section 70 of the WBGST Act, 2017 for production of documents concerning Financial Years 2021-22 to 2023-24. The petitioner nevertheless contended that the decision to block the Electronic Credit Ledger under Rule 86A had already been taken without giving it an opportunity to rebut the allegations. The source also records reliance upon Section 70 of the WBGST Act/CGST Act framework.
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