High Court of Madras
Zigma Machinery & Equipment Solutions v. Assistant Commissioner Coimbatore-I Division
WP NO. 32816 OF 2026
The ruling in brief
Where assessee obtained interim stay against recovery measures initiated following assessment, such stay order only suspended recovery action and did not affect prior blocking of electronic credit ledger, meaning amounts in electronic credit ledger could not be debited for recovery during validity of stay, but order itself did not unfreeze or impact pre-existing ledger blockage.
Where electronic credit ledger was blocked after assessment for recovery of dues, such negative blocking fell within recovery modes under Section 79, as its wide ambit covers deduction from money or goods, garnishee action, distraint and sale, and recovery with Collector or Magistrate assistance, whereas Rule 86A deals only with provisional restriction before liability determination, so plea against negative blocking under Section 79 was rejected
Provisions considered
Section 79 of Central Goods and Services Tax Act, 2017/Tamil Nadu Goods and Services Tax Act, 2017 - Rule 86A of Central Goods and Services Tax Rules, 2017/Tamil Nadu Goods and Services Tax Rules, 2017; Section 79 of Central Goods and Services Tax Act, 2017/Tamil Nadu Goods and Services Tax Act, 2017 - Rule 86A of Central Goods and Services Tax Rules, 2017/Tamil Nadu 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.