IN THE HIGH COURT OF JUDICATURE AT MADRAS

DATED : 12.12.2025

CORAM :

THE HONOURABLE MR.JUSTICE C.SARAVANAN

MMTC PAMP India Private Limited,

Represented by its Authorised Signatory

Sh.Ravi Garhwal ... Petitioner

Vs.

1.The Assistant Commissioner,

Coimbatore-IIID Range,

No-1662A, 2nd Floor,

Aditya Towers,

Trichy Road,

Ramanathapuram,

Coimbatore – 641 045.

2.Additional / Joint Commissioner,

Central Goods and Service Tax,

6 / 7, A.T.D.Street, Race Course Road,

Coimbatore – 641 018.

3.Superintendent of CGST and Central Excise,

Coimbatore, IID, Range No.1662A,

2nd Floor,

Adithya Towers,

Trichy Road,

Ramanathapuram,

Coimbatore – 641 045. ... Respondents

Prayer: Writ Petition filed under Article 226 of the Constitution of India, for issuance of a Writ of Mandamus, to direct the Respondents to unblock the ITC amounting to Rs.39,90,404/- available in the Electronic Credit Ledger of the Petitioner and permit them to utilize the same towards payment of outward tax liability and to hold that the Impugned blocking is illegal, arbitrary and without jurisdiction.

For Petitioner : Mr.Joseph Prabakar For Respondents : Mr.G.Meganathan Junior Standing Counsel

ORDER

In this Writ Petition, the Petitioner has challenged the Impugned Blocking of the Input Tax Credit of the Petitioner on 16.04.2025.

2. The blocking of the Input Tax Credit was purportedly made on

14.05.2025. The Impugned blocking of the Input Tax Credit for a sum of Rs.39,90,404/- has preceded an internal communication by the Directorate General of Goods and Service Tax Intelligence, Jaipur Zonal Unit to the 2^nd Respondent within whose jurisdiction the Petitioner’s Private Limited was registered.

3. In response to the same, the Petitioner has also sent a Representation Letter to the 1^st Respondent on 22.05.2025. The blocking of the Input Tax Credit is purportedly in accordance with Rule 86A(1) of the respective GST Rules.

4. As a matter of fact, Sub-Clause (2) to Rule 86A of the respective GST Rules contemplates the Commissioner, or the Officer authorized by him under Sub-Rule (1) may, upon being satisfied that conditions for disallowing debit of Electronic Credit Ledger, no longer exist can allow such debit.

5. Sub-Clause (2) to Rule 86A of the respective GST Rules is reproduced below:-

“Rule 86A – Conditions of use of amount available in Electronic Credit Ledger -

(1)…..

(2)The Commissioner, or the Officer authorized by him under Sub-Rule (1) may, upon being satisfied that conditions for disallowing debit of Electronic Credit Ledger as above, no longer exist, allow such debit.”

6. Considering the fact that the Petitioner has replied vide Representation dated 22.05.2025 and no decision has been taken as is required under Sub-Clause (2) to Rule 86A of the respective GST Rules, this Writ Petition stands disposed of by directing the 2^nd Respondent to pass appropriate orders on the Representation dated 22.05.2025 of the Petitioner within a period of two weeks from the date of receipt of a copy of this order.

7. This Writ Petition stands disposed of with the above observations. No costs.

12.12.2025 Neutral Citation : Yes / No arb To:

1.The Assistant Commissioner, Coimbatore-IIID Range, No-1662A, 2nd Floor, Aditya Towers, Trichy Road, Ramanathapuram, Coimbatore – 641 045.

2.Additional / Joint Commissioner, Central Goods and Service Tax, 6 / 7, A.T.D.Street, Race Course Road, Coimbatore – 641 018.

3.Superintendent of CGST and Central Excise, Coimbatore, IID, Range No.1662A, 2nd Floor, Adithya Towers, Trichy Road, Ramanathapuram, Coimbatore – 641 045.

C.SARAVANAN, J.

arb

12.12.2025