Sitevi Infraprojects Private Limited vs. Union Of INDIA

CW/18672/2024HC RajasthanGSTCNR RJHC02103308202424 February 2026Bench: INDERJEET SINGH,RAVI CHIRANIA2 pages

AI SummaryRemanded

Facts

The petitioner, Sumetco Alloys Private Limited, filed a writ petition challenging an action taken by the revenue authorities. The respondents, including the Deputy Commissioner, State Tax, and Joint Commissioner, Enforcement Wing, were involved. The core of the dispute appears to relate to the blocking of the petitioner's Electronic Credit Ledger under the CGST Act. The tax period(s) and the specific amount in dispute are not explicitly stated in the provided text. The procedural history indicates that the matter reached the High Court of Judicature for Rajasthan, Bench at Jaipur, through a writ petition. The respondents' counsel informed the court that the period for which the Electronic Credit Ledger was blocked had expired.

Held

The Court held that the blocking of the Electronic Credit Ledger under Rule 86A(3) of the CGST Act, 2017, is indeed for a period of one year. The respondents' counsel submitted that this one-year period had expired. The petitioner's counsel did not dispute this submission. Consequently, the Court found that the writ petition had become infructuous. The Court disposed of the writ petition with liberty granted to the petitioner to pursue appropriate remedies in the future if the need arises, in accordance with the law. No specific finding was made on the merits of the original challenge to the blocking of the ledger, as the matter was decided on the ground of it becoming infructuous.

Key Issues

1. Whether the blocking of the Electronic Credit Ledger under Rule 86A(3) of the CGST Act, 2017, is limited to a period of one year, and if so, whether the present petition has become infructuous upon the expiry of this period? Petitioner's Contention: The petitioner's counsel did not dispute the position of law presented by the respondents regarding the one-year limitation for blocking the Electronic Credit Ledger. Therefore, no specific argument was advanced by the petitioner on this point. Revenue/State's Contention: The respondents argued that as per Sub-Rule 3 of Rule 86A of the CGST Act, 2017, the blocking of the Electronic Credit Ledger is permissible only for a period of one year. They contended that this one-year period had already expired, rendering the present writ petition infructuous due to the changed circumstances.

Sections Cited

Rule 86A(3)

AI-generated summary — verify with the full judgment below

Cause title — parties, addresses and appearances

[2026:RJ-JP:8586-DB] HIGH COURT OF JUDICATURE FOR RAJASTHAN BENCH AT JAIPUR D.B. Civil Writ Petition No. 11921/2024 Sumetco Alloys Private Limited, G-740, Riico Industrial Area, Bhiwadi, Alwar, Rajasthan,301019 Through Its Authorized Signatory Priyanka Bhandari S/o Nirmal Kumar Bhandari, Aged 39 Years, R/o A-1/170, 2Nd Floor, Paschim Vihar, Delhi-110063 Working As Managing Director. ----Petitioner Versus 1. Deputy Commissioner, State Tax, Circle-A, Bhiwadi, Kar Bhawan, Uit Sector-6, Bhiwadi-301019. 2. Joint Commissioner, Circle-C, Enforcement Wing-Iii, Kar Bhawan, Ambedkar Circle,jaipur-302005. 3. State Of Rajasthan, Through Chief Commissioner, State Tax , Rajasthan, State Taxes Department, Kar Bhawan, Ambedkar Circle, Jaipur-302005. 4. Union Of India, Through The Revenue Secretary, Department Of Revenue, Ministry Of Finance, North Block, New Delhi-110001 ----Respondents Connected With D.B. Civil Writ Petition No. 18672/2024 Sitevi Infraprojects Private Limited, Having Its Registered Office At Plot No. 225, Gate No. 5 Rajat Garh Colony, Bundi, Rajasthan - 323001 Through Its Authorised Representative Mr. Kuldeep Singh Sainani ----Petitioner Versus 1. Union Of India, Through The Secretary, Department Of Revenue, Ministry Of Finance, North Block, New Delhi- 110001. 2. Additional Director General, Directorate General Of Gst Intelligence, Gurugram Zonal Unit, Plot No. 44, Sector- 32, Gurugram-122001. 3. Joint Director, Directorate General Of Gst Intelligence, Gurugram Zonal Unit, Plot No. 44, Sector-32, Gurugram- 122001. [2026:RJ-JP:8586-DB] (2 of 2) [CW-11921/2024] 4. State Of Rajasthan, Through The Finance Secretary, Finance Department, 1St Floor, Main Building, Government Secretariat, Janpath, Jaipur-302005. 5. Commissioner, Commercial Taxes Department, Kar Bhawan, Ambdekar Circle, Japiur, Rajasthan-302005. 6. Deputy Commissioner, State Tax, Commercial Tax Department, Ward-Cto/ac, Circle-Bundi (Raj.), Near Bus Stand, Near Ekkhambhekichhatri, Bundi-323001. ----Respondents For Petitioner(s) : Mr. Amit Milani, Advocate. Ms. Priyamvada, Advocate. Mr. Sakshya Jain, Advocate. Ms. Kashni, Advocate. Ms. Priyanka Singal, Advocate. For Respondent(s) : Ms. Mahi Yadav, Additional Advocate General. Mr. Kinshuk Jain, Senior Standing Counsel. HON'BLE MR. JUSTICE INDERJEET SINGH HON'BLE MR. JUSTICE RAVI CHIRANIA

Order 24/02/2026 Counsel for the respondents submits that as per Sub-Rule 3 of Rules 86A of CGST Act, 2017, blocking of Electronic Credit Ledger is only for a period of one year and that period has already expired. Counsel further submits that the present writ petition has become infructuous in view of the changed circumstances.

Counsel for the petitioner has not disputed the position of law.

In that view of the matter, this writ petition is disposed of with liberty to the petitioner to take appropriate remedy if need so arises in future in accordance with law. (RAVI CHIRANIA),J (INDERJEET SINGH),J Tushar/176-177

Reproduced from the public record of the Rajasthan High Court. Verify against the court's own copy before relying on it. Income tax judgments are on bharattax.net.