M/S Spl Motors P LTD vs. Union Of INDIA And Others
Held
The Court held that blocking ITC in excess of the available credit in the ECL, creating a negative balance, is not permissible under Rule 86A. Such an action is considered unsustainable and without jurisdiction.
Facts
The petitioner's Electronic Credit Ledger (ECL) had its Input Tax Credit (ITC) blocked in a negative balance by the respondents. This action was taken without prior intimation or notice, allegedly violating principles of natural justice and Rule 86A of the CGST/HGST Acts.
Key Issues
Whether Rule 86A permits blocking of ITC in excess of the credit available in the Electronic Credit Ledger, creating a negative balance.
Sections Cited
Rule 86A, Section 73, Section 74
AI-generated summary — verify with the full judgment below
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CWP-32560-2024
254-b IN THE HIGH COURT OF PUNJAB AND HARYANA
AT CHANDIGARH
CWP-32560-2024
Date of Decision: November 19, 2025
M/S SPL MOTORS (P) LTD.
.....Petitioner
Versus
UNION OF INDIA AND OTHERS
..... Respondents
CORAM:- HON'BLE MRS. JUSTICE LISA GILL
HON'BLE MR. JUSTICE PARMOD GOYAL
Present: Mr. Sandeep Goyal, Senior Advocate with Mr. Rishab Singla, Advocate for the petitioner.
Ms. Sharmila Sharma, Advocate for the respondents.
****
LISA GILL, J.
It is submitted that prayer in this writ petition is restricted to action of respondents of blocking Electronic Credit Ledger (ECL) of petitioner and for deleting entry dated 29.04.2024 through which Input Tax Credit has been blocked in negative by the respondents, statedly in violation of provisions of Rule 86A of Central Goods and Services Tax Act, 2017 and Haryana Goods and Services Tax Act, 2017 and in violation of principles of natural justice. RITU SHARMA 2025.11.28 12:27 I attest to the accuracy and integrity of this document
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CWP-32560-2024
Learned co
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