Abhishek Goyal Vs Union of India (Punjab And Haryana High Court)
The writ petition before the Punjab and Haryana High Court was confined to the challenge against the action of the respondents in blocking the petitioner’s Electronic Credit Ledger (ECL) by creating negative balances through entries dated 12.06.2025, 02.09.2025, and 03.10.2025. The petitioner contended that such negative blocking of Input Tax Credit (ITC) was carried out under Rule 86A of the Goods and Services Tax Rules, 2017 in violation of the statutory framework and principles of natural justice.
Both parties agreed that the sole legal question requiring adjudication was whether Rule 86A permits the Commissioner or an authorised officer to block a taxpayer’s ECL by an amount exceeding the ITC actually available in the ledger at the time the order is passed. In view of the narrow legal issue, the Court proceeded to hear the matter without requiring a formal reply from the respondents.
The petitioner, an active business entity registered under the Punjab Goods and Services Tax Act, 2017, argued that the respondents had blocked ITC without prior notice and had created an artificial negative balance in the ECL. This, according to the petitioner, effectively disabled the utilisation of legitimately availed ITC for discharge of tax liabilities. It was submitted that Rule 86A does not authorise blocking of ITC beyond what is available in the ECL at the relevant time, and that the power under Rule 86A is strictly confined to restricting debit of existing credit.
