Section 107(6) CGST Act

Blocked Is Not Paid: Delhi High Court Holds Input Tax Credit Restricted Under Rule 86A Cannot Satisfy the Mandatory Pre-Deposit for a GST Appeal

A registered person facing a Rs. 33.32 lakh GST demand wanted Rs. 3.33 lakh of its own input tax credit — already frozen under Rule 86A — treated as satisfying the ten per cent pre-deposit needed to appeal. The Delhi High Court refused: a restriction under Rule 86A prevents debit from the electronic credit ledger, it does not appropriate the credit toward any demand, and the two authorities holding otherwise on unrestricted credit had no application to credit that is actually blocked.