Neutral Citation No. - 2025:AHC:74980-DB Chief Justice's Court Case :- WRIT TAX No. - 628 of 2025 Petitioner :- Dutt Metal Craft Respondent :- State of U.P. and another Counsel for Petitioner :- Abhinav Gaur Counsel for Respondent :- C.S.C., Dhananjay Awasthi Hon'ble Arun Bhansali,Chief Justice Hon'ble Kshitij Shailendra,J. 1. This petition has been filed by the petitioner aggrieved of the action of the respondents in passing the order dated 24.01.2025 (Annexure-9 to the writ petition) under Section 86A of the Central Goods and Services Tax Act, 2017 (for short 'the Act'). 2. Submissions have been made that though the order passed under Section 86A of the Act, indicated blocking in the electronic credit register to the tune of Rs. 4,53,79,497/-, the respondents, in fact, have vide Annexure-10 to the writ petition debited the amount to the tune of Rs. 46,01,645/- in the electronic credit register of the petitioner and now an amount to the tune of Rs. 4,07,77,852/- is being shown, as negative balance. 3. Though the plea in the petition pertains to the action of the respondents in negative blocking in the electronic credit register being contrary to the powers under Rule 86A of the Central Goods and Services Tax Rules, 2017 (for short 'the Rules') a submission was made on 10.03.2025, wherein the respondents were granted time to indicate as to whether the amount of Rs. 46,01,645/-, which was lying in the credit of the petitioner on the date of order, has been debited and/or the same has only been blocked or lien has been credited to which, instructions have been produced, inter alia, indicating that the amount of Rs. 46,01,645/- has been blocked and not debited as claimed by the petitioner. 4. So far as further submissions made as to creating the negative lien is concerned, this Court in M/s. R.M. Dairy Products LLP v. State of U.P. and others: 2021 (7) ADJ 449 has held the same as permissible, however, another Bench in Sarvottam Rolling Mills Pvt. Ltd v. Joint Commissioner State Tax Corporate and others: Writ Tax No. 1182 of 2022 has ordered for referring of the matter to a Larger Bench, where the issue remains pending. 5. In the circumstances of the case, wherein the plea raised by the petitioner, essentially pertains to the debit entry having been made by the respondents, qua a sum of Rs. 46,01,645/-, which aspect has been clarified and indicated as having been blocked only, the apprehension as expressed by the petitioner and the foundation for filing the petition is taken care of. 6. Consequently, the petition stands disposed of. Order Date :- 8.5.2025 AKShukla/Pkb (Kshitij Shailendra, J) (Arun Bhansali, CJ) Digitally signed by :- ANIL KUMAR SHUKLA High Court of Judicature at Allahabad