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The writ petition was filed to challenge the validity of Rule 86-A of the Uttar Pradesh Goods and Services Tax Rules, 2017. The order blocking the Input Tax Credit came to an end on its own by operation of law.

Rule 86A of the CGST Rules, 2017 — Blocking of ITC ----The petitioner challenged the order dated 10.07.2020, whereby the petitioner’s ITC upto Rs. 2,67,16,352/- available in the Electronic Credit Ledger had been blocked. The court observed that the order under Rule 86-A of the Rules was passed on 10.07.2020. By virtue of clear language of subRule (3) of Rule 86-A, the life of that direction was confined to one year from the date of direction coming into existence. Thus, the order blocking the Input Tax Credit upto Rs. 2,67,16,352/- available in the Electronic Credit Ledger of the petitioner came to an end on its own, by operation of law, on 09.07.2021. No other order has been shown as may allow the Input Tax Credit to remain blocked beyond 09.07.2021.

Held that:- The Hon’ble High Court disposed the petition leaving it open to either party to take such other or further action as law permits.

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