HIGH COURT OF JUDICATURE AT ALLAHABAD M/S Pilcon Infrastructure Pvt. Ltd.

.....Petitioner(s)

Versus State of U.P. and Another .....Respondent(s)

Counsel for Petitioner(s) : Aloke Kumar, Puneet Arun Counsel for Respondent(s) : C.S.C.

Court No. - 3 HON'BLE SAUMITRA DAYAL SINGH, J.

HON'BLE INDRAJEET SHUKLA, J.

1. Heard Shri Aloke Kumar along with Shri Adarsh Singh as counsel for the petitioner and Shri Ankur Agarwal, learned counsel for the respondent.

2. Present petition has been filed for the following relief:

"Issue a suitable writ, order or direction in the nature of mandamus directing the Respondent no.2 to unblock the Input Tax Credit (ITC) amounting to Rs. 13,96,220/-

available in the Electronic Credit Ledger (ECL) of the petitioner."

3. On the strength of e-mail communication dated 24.07.2025 issued by Goods and Services Tax Network (GSTN) to the petitioner, it has been stressed, 'reasons to believe' required to be 'recorded in writing' under Rule 86A of the U.P.G.S.T. Rules 2017 (hereinafter referred to as the 'Rules') have not been recorded. To the extent that jurisdictional requirement has not been fulfilled, the consequence of blocking of Input Tax Credit (ITC in short), visited on