Case Details: Commissioner of Central Goods and Service Tax Versus Karuna Rajendra Ringshia (2025) 32 Centax 449 (S.C.)
Judiciary and Counsel Details
- SUDHANSHU DHULIA and JOYMALYA BAGCHI, JJ.
- S/Sahri Raghavendra P. Shankar, A.S.G., Gurmeet Singh Makker, AOR,
- Karan Lahiri, Bhuvan Kapoor and Piyush Beriwal, Advs. for the Petitioner.
Facts of the Case
The petitioner challenged the action of the jurisdictional officer under CGST and Delhi GST in blocking the Electronic Credit Ledger (ECL) under Rule 86A of the CGST Rules and Delhi GST Rules. On the date when the blocking was enforced, there was a credit balance in the ECL, and the blocking of a higher amount resulted in a consequential negative balance. The petitioner contended that such negative blocking was not permissible under the provisions of Rule 86A. The High Court, by the impugned order, held that it is not permissible to block the debit of ITC in the ECL in a manner that results in a negative balance and that such blocking was not sustainable. The authorities were accordingly directed to lift the negative blocking forthwith, and the Department of Revenue thereafter filed a Special Leave Petition before the Supreme Court against the said order.
High Court Held
The Hon’ble Supreme Court held that no case for interference was made out and dismissed the Special Leave Petition filed against the impugned order. The Court thus upheld the finding of the High Court that blocking of the Electronic Credit Ledger, resulting in a negative balance, is not permissible under the applicable provisions. The dismissal confirms that such negative blocking is not sustainable in law.
List Of Cases Reviewed
Karuna Rajendra Ringshia v. Commissioner of Central Goods and Service Tax — [2024] 168 taxmann.com 249 (Delhi)/[2025] 107 GST 164 (Delhi) — SLP Dismissed [Para 2]
