3 crores of GST ITC blocked.
  • Zero hearing.
  • One vague notice.
  • It’s happening every month across India.
  • Rule 86A lets GST officers block Input Tax Credit.
  • No court order.
  • No adjudication.
  • Just “reasons to believe.”

Here’s the problem:

  • Most tax/finance teams don’t even know when it’s happening.
  • Until credit disappears from their ledger…
  • And no one tells them why.
→ The supplier was non-existent → The goods were “deemed” not received → Or the tax wasn’t paid to the govt And suddenly, your working capital is stuck in limbo.

Here’s how to deal with it:
Know the 3 buckets of 86A before it hits you:

1. Basic Grounds:

Officers can block ITC based on supplier non-existence, fake invoices, or tax not paid.

2. Future Credit Blocking:

Courts disagree, some say future or used credit can’t be blocked, others allow it.

3. Writ or Appeal:

You can challenge it through a writ petition. In some cases, an appeal under Section 107 is possible.

  • You can challenge it through a writ petition. In some cases, an appeal under Section 107 is possible.
  • Because this isn’t about tax planning.
  • It’s about operational defense.
  • I’ve worked with clients where 1 blocked ITC disrupted payroll.
  • Not because the credit wasn’t legit.
  • But because the response wasn’t ready.