Neutral Citation No. - 2025:AHC:135160-DB Court No. - 3 Case :- WRIT TAX No. - 3070 of 2025 Petitioner :- M/S Jai Balaji Maharaj Polymers India P Ltd. Respondent :- Union Of India And 3 Others Counsel for Petitioner :- Nitin Sharma,Praveen Kumar Counsel for Respondent :- A.S.G.I.,Krishna Agarawal,Saumitra Singh Hon'ble Shekhar B. Saraf,J. Hon'ble Praveen Kumar Giri,J. 1. This is a writ petition under Article 226 of the Constitution of India, wherein the writ petitioner is aggrieved by the blocking of its Electronic Credit Ledger by an order dated June 20, 2025, passed by the Commissioner, Central Goods and Services Tax Act, Ghaziabad. 2. Learned counsel appearing on behalf of the petitioner has raised several issues, and after considering the same, this Court had framed the following three issues to answer in the present writ petition : "I. Whether the 'reasons to believe' in Rule 86A of the CGST Rules, 2017 arrived at by the officer concerned may be based on information received by him from other sources and whether the 'reasons to believe' are prima facie in nature only? II. In the event the 'reasons to believe' are present, is the officer concerned required to provide a pre-decisional hearing to the assessee before blocking the Electronic Credit Ledger under Rule 86A? III. Whether such blocking of Electronic Credit Ledger can exceed the amount that is present on the date, such blocking of Electronic Credit Ledger is done?" 3. However, after hearing the learned counsel appearing on behalf of petitioner and the respondent, we are of the view that without answering the above framed questions of law and for the ends of justice, this matter should be remanded to the Commissioner, CGST Act, Ghaziabad, for reconsideration of the electronic blocking done by him. The petitioner is directed to file reply/objection to the blocking that has been done within one week from date. 4. By consent of the parties, we are fixing the date of personal hearing to be on August 25, 2025 at 11.00 AM at the office of the Commissioner, CGST Act, Ghaziabad. The Commissioner, CGST Act, Ghaziabad, should pass a reasoned order expeditiously, preferably within a period of one week from the date of hearing. 5. We make it clear that we have not gone into the other prayers of the petitioner with regard to the refund that the petitioner has claimed. 6. It is to be further noted that issue No.III with regard to blocking of Electronic Credit Ledger has been referred to a larger Bench vide an order dated January 24, 2023 by the Division Bench presided by the Hon'ble the Chief Justice in Writ Tax No. 1182 of 2022 (Sarvottam Rolling Mills Pvt. Ltd. vs. Joint Commissioner, State Tax Corporate and others). As the issue is critical in nature, and there are divergent views that have emerged from different High Courts, we direct the Registry to place this order before the Hon'ble Chief Justice for due consideration. 7. In light of the above directions, this writ petition is disposed of. Order Date :- 11.8.2025 DKS (Praveen Kumar Giri,J.) (Shekhar B. Saraf, J.) Digitally signed by :- DEEPAK KUMAR SRIVASTWA High Court of Judicature at Allahabad