CWP-14419-2026 IN THE HIGH COURT OF PUNJAB AND HARYANA AT M/s Shreyash Retail Private Limited The Assistant Commissioner of State Tax and another CORAM : HON’BLE MR. JUSTICE HON’BLE MS. JUSTICE LAPITA BANERJI Present : Mr. Kumar Vislaksha, Advocate (through video conferencing) Mr. Abhinav Mr. Ajitesh Dayal, Advocate for the petitioner. Mr. Saurabh Kapoor, Additional Advocate General, Punjab DEEPAK SIBAL This p input tax credit conveyed to the petitioner through email d (Annexure P-1) blocked without passing any order. 2. Learned counsel for the parties have been heard. 3. Rule 86A of (hereinafter referred to as ‘the Rules’) Commissioner or an officer authorized by him in this regard, not below the rank of Assistant Commissioner, can block an assessee’s ITC availa the assessee’s electronic credit ledger but only when such officer has reasons to believe that the ITC available in the assessee’s electronic credit 2026 (O&M) Sr. No.229 IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH CWP-14419 Date of Decision : M/s Shreyash Retail Private Limited Versus The Assistant Commissioner of State Tax and another HON’BLE MR. JUSTICE DEEPAK SIBAL HON’BLE MS. JUSTICE LAPITA BANERJI Mr. Kumar Vislaksha, Advocate (through video conferencing) Mr. Abhinav Sood, Advocate, Mr. Ajitesh Dayal, Advocate for the petitioner. Mr. Saurabh Kapoor, Additional Advocate General, Punjab *** DEEPAK SIBAL, J. (Oral) This petition is directed against the input tax credit conveyed to the petitioner through email d 1) on the ground that the petitioner’s input tax credit has been ocked without passing any order. Learned counsel for the parties have been heard. Rule 86A of the Central Goods and Services Tax Rules, 2017 (hereinafter referred to as ‘the Rules’) Commissioner or an officer authorized by him in this regard, not below the rank of Assistant Commissioner, can block an assessee’s ITC availa the assessee’s electronic credit ledger but only when such officer has reasons to believe that the ITC available in the assessee’s electronic credit IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH 14419-2026 (O&M) Date of Decision : 12.05.2026 …Petitioner The Assistant Commissioner of State Tax and another…Respondents DEEPAK SIBAL HON’BLE MS. JUSTICE LAPITA BANERJI Mr. Saurabh Kapoor, Additional Advocate General, Punjab etition is directed against the blocking of the petitioner’s input tax credit conveyed to the petitioner through email dated 13.01.2026 on the ground that the petitioner’s input tax credit has been Learned counsel for the parties have been heard. the Central Goods and Services Tax Rules, 2017 (hereinafter referred to as ‘the Rules’) clearly provides that the Commissioner or an officer authorized by him in this regard, not below the rank of Assistant Commissioner, can block an assessee’s ITC available in the assessee’s electronic credit ledger but only when such officer has reasons to believe that the ITC available in the assessee’s electronic credit VANDANA 2026.05.14 09:45 I attest to the accuracy and integrity of this document CWP-14419-2026 ledger has been fraudulently availed by the assessee or that the assessee is ineligible to avail the 4. It is not existing in its electronic credit ledger, no order was passed by the competent authority recording therein the reasons as to why he believe the petitioner’s ITC, existing in its electronic credit ledger, should be blocked. Thus, the impugned blocking of the petitioner’s ITC Rule 86-A of the Rules. the petitioner’s ITC, existing i order its release afresh against the petitioner in accordance with law. 5. Disposed of. May 12, 2026 vandana Whether speaking/reasoned : Whether reportable 2026 (O&M) ledger has been fraudulently availed by the assessee or that the assessee is ineligible to avail the ITC existing in its electronic credit ledger. It is not disputed that prior to blocking of the petitioner’s ITC existing in its electronic credit ledger, no order was passed by the competent authority recording therein the reasons as to why he believe the petitioner’s ITC, existing in its electronic credit ledger, should be Thus, the impugned blocking of the petitioner’s ITC A of the Rules. Therefore, we unhesitantly the petitioner’s ITC, existing in its electronic credit ledger is order its release. However, the respondents would be at liberty to proceed afresh against the petitioner in accordance with law. Disposed of. (DEEPAK SIBAL JUDGE (LAPITA BANERJI) JUDGE , 2026 ther speaking/reasoned : Yes/No Whether reportable : Yes/No ledger has been fraudulently availed by the assessee or that the assessee is ITC existing in its electronic credit ledger. that prior to blocking of the petitioner’s ITC existing in its electronic credit ledger, no order was passed by the competent authority recording therein the reasons as to why he believed that the petitioner’s ITC, existing in its electronic credit ledger, should be Thus, the impugned blocking of the petitioner’s ITC contravenes unhesitantly hold that the blocking n its electronic credit ledger is illegal and However, the respondents would be at liberty to proceed afresh against the petitioner in accordance with law. DEEPAK SIBAL) JUDGE (LAPITA BANERJI) JUDGE VANDANA 2026.05.14 09:45 I attest to the accuracy and integrity of this document