High Court of Delhi
Spherion Solutions (P.) Ltd. v. Additional Commissioner Adjudication CGST, Delhi North
W.P. (C) NO. 3418 OF 2026
The ruling in brief
Where petitioner’s ITC in electronic credit ledger was blocked under Rule 86A, requested adjustment of blocked credit for pre-deposit against confirmed IGST demand was declined, since blocking does not constitute payment or appropriation towards an adjudicated demand and debit cannot occur until restriction is removed or modified, thus only unblocked ECL credit may be used for pre-deposit, not mandatorily cash ledger
Provisions considered
Section 107, read with section 49, of Central Goods and Services Tax Act, 2017/Delhi Goods and Services Tax Act, 2017 - Rule 86A of Central Goods and Services Tax Rules, 2017/Delhi Goods and Services Tax Rules, 2017
This summary is for general information and is not legal advice. Read the full decision and the applicable law before relying on it.