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TMI Blog2024 (9) TMI 1543X X X X Extracts X X X X X X X X Extracts X X X X ..... atija and Mr Udit Sharma, Advocates. Mr. Mohit Gupta, Advocate, Mr. Rajesh Mahna, Mr. Ramanand Roy, Mr. Mayank Routs, Ms Silky Wadhwa and Mr Shiva Narang, Advocates. Mr. Mayank Routs, and Ms Silky Wadhwa and Mr Shiva Narang, Advocates. For the Respondent : Mr Harpreet Singh, SSC, Ms Suhani Mathur, and Mr Jatin Kumar Gaur, Advocates. Mr Harpreet Singh, SSC, Ms Suhani Mathur, and Mr Jatin Kumar Gaur, Advocates. Mr. Anurag Ojha, Sr SC and Mr. Subham Kumar, Mr Kumar Abhishek, Mr Dipak Raj Singh, Advocates for R2 and R3. Mr R Ramchandran, Sr SC for R3., Mr. Rajeev Aggarwal, ASC Ms. Shaguftha Hameed Mr. Prateek Badhwar and Mr. Shubam Goel, Advocates for Department of Trade and Taxes Delhi, Mr Abhinav Kalia, and Mr Ajit Kumar Kalia, Advocates for R1 to R3. Mr.Anurag Ojha, Sr SC, Mr. Subham Kumar, Mr Kumar Abhishek, Mr Dipak and Mr Vipul Kumar, Advocates for R4. JUDGMENT VIBHU BAKHRU, J THE CONTROVERSY 1. The petitioners, in these batch of petitions, are taxpayers and are registered under the Central Goods and Services Tax Act, 2017 (hereafter the CGST Act) / Delhi Goods and Services Tax Act, 2017 (hereafter the DGST Act). They impugn the respective orders passed by the Commissioner/o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... her Rule 86A of the Rules permits the Commissioner or an officer authorized by him, to block a taxpayer's ECL (Electronic Credit Ledger) by an amount exceeding the credit available at the time of issuance of the said order? SUBMISSIONS OF THE COUNSEL 5. The learned counsel appearing for the petitioners referred to the decision of the Gujarat High Court in Samay Alloys India Pvt. Ltd. v. State of Gujarat Neutral Citation No. 2022:GUJHC:6969-DB and the decision of the Telangana High Court in Laxmi Fine Chem vs Assistant Commissioner W.P.No.5256/2024 decided on 18.03.2024, which covers the controversy. 6. They submit that a taxpayer has a vested right in utilising the ITC as available in his ECL for discharge of its dues or in appropriate cases for seeking a refund of the same. Thus, the same could not be blocked or appropriated except by a specific statutory provision to the said effect. They contend that Rule 86A of the Rules is required to be strictly interpreted and a taxpayer's ECL can be blocked only to the extent as permitted under Rule 86A of the Rules. They submit that the said provision is unambiguous and therefore, is required to be interpreted by applying the Rule of li ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er's ECL on the date of the issuance of the order. 10. Mr Rajiv Aggarwal, appearing for the Revenue in W.P.(C) Nos. 5395/2024 and 5397/2024, submitted that the language of Rule 86A of the Rules is clear and therefore, the same is required to be interpreted in its literal sense. He referred to the decision of the Supreme Court in Britannia Industries Ltd. v. CIT (2006) 1 SCC 646 in support of his contention. He also referred to the decision of the Constitution Bench of the Supreme Court in Commissioner of Customs (Import), Mumbai v. Dilip Kumar and Company & Ors. (2018) 9 SCC 1 and contended that the statute must be construed according to the intent of the legislature. He submitted that the intent of framing Rule 86A of the Rules was clearly to deprive the taxpayer of availing the ITC to the extent that such ITC was availed fraudulently or was ineligible. He submitted that the power to block the ITC is confined to sum equivalent to the ineligible and fraudulently availed ITC. 11. Next, he submitted that Rule 86A of the Rules use the words 'equivalent to such credit' instead of the words 'equivalent to such available credit'. He submitted that this clearly indicates the legislative ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e nature of a 'privilege'. Although, a taxpayer may have beneficial interest in tax credit, it cannot be enforced against the State beyond the scheme of the Rules conferring such benefit. He referred to the decision of the Supreme Court in ALD Automotive Pvt. Ltd. v. Commercial Tax Officer now upgraded as Assistant Commissioner (CT) & Ors. (2019) 13 SCC 225 in support of his contention. 16. He submitted that the ITC must, thus, be viewed as an exemption and therefore, the principle governing exemption notifications would necessarily apply. He referred to the decision of the Supreme Court in Commissioner of Customs (Import), Mumbai v. Dilip Kumar and Company & Ors and submitted that where two views are possible in case of an exemption notification, the one which is favourable to the Revenue is required to be accepted. 17. He submitted that Rule 86A of the Rules must be interpreted by applying principles of purposive interpretation and therefore, Rule 86A of the Rules must be interpreted in a manner so as to further the remedy sought to be achieved. 18. He submitted that the taxpayer would have no right to deduct the input tax, which is founded on an abusive practice. He contended ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... argeable on the supplies at multiple stages. However, a taxpayer is entitled to credit for the tax paid by him on the supplies received subject to the conditions as set out under the relevant statues. 23. Chapter V of the CGST Act and also the corresponding State and Union Territory legislations, contain provisions regarding ITC. For convenience and brevity, we shall refer to the provisions of the CGST Act for addressing the controversy in these petitions. It is relevant to refer to Sub-sections (1) and (2) of Section 16 of the CGST Act. The same are set out below: "16. Eligibility and conditions for taking input tax credit. - (1) Every registered person shall, subject to such conditions and restrictions as may be prescribed and in the manner specified in section 49, be entitled to take credit of input tax charged on any supply of goods or services or both to him which are used or intended to be used in the course or furtherance of his business and the said amount shall be credited to the electronic credit ledger of such person. (2) Notwithstanding anything contained in this section, no registered person shall be entitled to the credit of any input tax in respect of any supp ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of supply of goods or services or both along with tax payable thereon." 24. In terms of Section 16 (1) of the CGST Act, every registered person is entitled to take credit of the input tax charged on supply of goods or services or both, which is used or intended to be used in furtherance of his business. The said amounts are to be credited to the taxpayer's ECL. However, the entitlement is subject to the conditions and restrictions as may be prescribed and, in the manner, as posited under Section 49 of the CGST Act. Sub-section (2) of Section 16 of the CGST sets out the conditions, which if not complied with disentitles a registered person of any credit of input tax in respect of supply of goods or services or both. Sub-section (3) of Section 16 of the CGST Act disentitles a taxpayer for any ITC in respect of a depreciable capital goods where the registered person has availed of depreciation on the tax component of the value of such capital goods. Sub-section (4) of Section 16 of the CGST Act sets out the time limit within which a registered person is entitled to take ITC. 25. Section 17 of the CGST Act contains the provisions for apportionment of the ITC in respect of goods or se ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ECL of a registered person can be used. Section 49A and 49B of the CGST Act prescribes the manner of utilization of the ITC and the order in which the ITC is required to be utilized. 30. A brief purview of the provisions of the CGST Act clearly indicate that a taxpayer is entitled to ITC only to the extent as provided under the CGST Act and subject to the stipulated conditions being satisfied. There is no cavil that if the conditions as set out under the CGST Act are not satisfied, the registered taxpayer would not be entitled to avail and utilize the ITC in respect of supplies received by it. The right to avail and utilize the ITC is thus a statutory right, which accrues by virtue of the provisions of the CGST Act and is subject to the conditions as set out therein. This right to avail and utilize the ITC is a valuable right. It is, undeniably, an asset, which vests with a taxpayer if the taxpayer satisfies all the stipulated conditions for such entitlement. 31. In ALD Automotive Pvt. Ltd. v. Commercial Tax Officer now upgraded as Assistant Commissioner (CT) & Ors. the Supreme Court had, in the context of Tamil Nadu Value Added Tax, 2006, observed as under: "34. The input cre ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... edit in that case were satisfied. It is relevant to note that in that case the question that fell for consideration was whether the taxpayer could be denied the benefit of Rule 57-E of the Central Excise Rules, 1944 as amended with effect from 15.04.1987. The amended Rule stipulated that where the duty paid on any inputs in respect of which credit has been allowed under Rule 57-A, and if the said duty is varied subsequently due to any reason resulting in refund or if the duty is varied due to change in classification resulting in the recovery, then the credit allowed shall also be varied accordingly, by adjustment in the credit account. The High Court held that Rule 57-E as amended was clarificatory and therefore did not affect the right of the manufacturer to claim MODVAT credit for the duty paid on inputs. The Supreme Court upheld the said view. It held that Section 57-E is procedural and therefore did not affect the substantive rights of the manufacturer. However, the Supreme Court also observed that the right would accrue to a manufacturer subject to him complying with the procedure of adjustment as contemplated under Rule 57-E as amended. 34. In Eicher Motors Ltd. & Anr. v. U ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... alue addition was also not of such a magnitude that the excise duty required to be paid on final products could have exceeded the total input credit allowed. Since the excess credit could not have been utilised for payment of the excise duty on any other product, the unutilised credit was getting accumulated. The stand of the assessees is that they have utilised the facility of paying excise duty on the inputs and carried the credit towards excise duty payable on the finished products. For the purpose of utilisation of the credit, all vestitive (sic) facts or necessary incidents thereto have taken place prior to 16-3-1995 or utilisation of the finished products prior to 16-3-1995. Thus the assessees became entitled to take the credit of the input instantaneously once the input is received in the factory on the basis of the existing Scheme. Now by application of Rule 57-F(4-A), the credit attributable to inputs already used in the manufacture of the final products and the final products which have already been cleared from the factory alone is sought to be lapsed, that is, the amount that is sought to be lapsed relates to the inputs already used in the manufacture of the final pro ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f for the purpose of manufacture of further goods." 35. In a subsequent decision in the case of Collector of Central Excise, Pune and Ors. v. Dai Ichi Karkaria Ltd. & Ors. (1999) 7 SCC 448 the Supreme Court held that the credit which is validly taken is indefeasible. The relevant extract of the said decision is set out below: "18. It is clear from these rules, as we read them, that a manufacturer obtains credit for the excise duty paid on raw material to be used by him in the production of an excisable product immediately it makes the requisite declaration and obtains an acknowledgment thereof. It is entitled to use the credit at any time thereafter when making payment of excise duty on the excisable product. There is no provision in the rules which provides for a reversal of the credit by the Excise Authorities except where it has been illegally or irregularly taken, in which event it stands cancelled or, if utilised, has to be paid for. We are here really concerned with credit that has been validly taken, and its benefit is available to the manufacturer without any limitation in time or otherwise unless the manufacturer itself chooses not to use the raw material in its excisab ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... availed based on fraudulent transactions like fake/bogus invoices etc. However, the subjective satisfaction should be based on some credible materials or information and also should be supported by supervening factor. It is not any and every material, howsoever vague and indefinite or distant remote or far-fetching, which would warrant the formation of the belief. (II) The power conferred upon the authority under Rule 86A of the Rules for blocking the ITC could be termed as a very drastic and far-reaching power. Such power should be used sparingly and only on subjective weighty grounds and reasons. (III) The power under Rule 86A of the Rules should neither be used as a tool to harass the assessee nor should it be used in a manner which may have an irreversible detrimental effect on the business of the assessee. (IV) The aspect of availing the credit and utilization of credit are two different stages. The utilization of credit is a vested right. No vested right accrues before taking credit. (V) The Government needs to apply its mind for the purpose of laying down some guidelines or procedure for the purpose of invoking Rule 86A of the Rules. In the absence of the same, Rule ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of satisfying the necessary conditions for the same. To the said extent, the said principle may be applicable for conditions to be satisfied for availing ITC. In Jayam & Company v. Assistant Commissioner & Anr (2016) 15 SCC 125. the Supreme Court applied the said principle while considering the interpretation of Section 3 and Section 19 of the Tamil Nadu Value Added Tax, 2006 and held as under: "12. It is a trite law that whenever concession is given by statute or notification etc. the conditions thereof are to be strictly complied with in order to avail such concession. Thus, it is not the right of the "dealers" to get the benefit of ITC but it is a concession granted by virtue of Section19. As a fortiori, conditions specified in Section 10 must be fulfilled. In that hue, we find that Section 10 makes original tax invoice relevant for the purpose of claiming tax. Therefore, under the scheme of the VAT Act, it is not permissible for the dealers to argue that the price as indicated in the tax invoice should not have been taken into consideration but the net purchase price after discount is to be the basis. If we were dealing with any other aspect do hors the issue of ITC as per t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ; (b) that the power under Rule 86A of the Rules is a drastic power and the same may have serious consequences for the taxpayer; and, (c) Rule 86A of the Rules concerns the power of the Commissioner, under defined circumstances, to interdict the taxpayer from accessing its valuable resource for discharging its dues or in given cases seeking a refund. It is not a provision, which imposes a condition to be satisfied by the taxpayer for availing the ITC. It is not a provision, which imposes a burden to be discharged by the taxpayer to be entitled to the ITC. 47. Insofar the principles regarding statutory interpretation are concerned, it is well settled that a statute must be interpreted as it reads. In CST v. Modi Sugar Mills Ltd. 1960 SCC OnLine SC 118 the Supreme Court had observed as under: ".....In interpreting a taxing statute, equitable considerations are entirely out of place. Nor can taxing statutes be interpreted on any presumptions or assumptions. The Court must look squarely at the words of the statute and interpret them. It must interpret a taxing statute in the light of what is clearly expressed: it cannot imply anything which is not expressed; it cannot import provisi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... problems before the legislature based on information derived from past and present experience. It may also be designed by use of general words to cover similar problems arising in future. But, from the very nature of things, it is impossible to anticipate fully the varied situations arising in future in which the application of the legislation in hand may be called for and words chosen to communicate such indefinite referents are bound to be in many cases lacking in clarity and precision and thus giving rise to controversial questions of construction. The process of construction combines both literal and purposive approaches. In other words the legislative intention i.e., the true or legal meaning of an enactment is derived by considering the meaning of the words used in the enactment in the light of any discernible purpose or object which comprehends the mischief and its remedy to which the enactment is directed..." 50. However, it is also well settled principle that if the words used in a statute are unambiguous, the same must be construed in their literal sense notwithstanding that the Court may be of the view that the legislative intent may have been different. If the legisla ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Wensleydale above and considered further below. The distinction requires to be drawn between a result which appears absurd merely in the sense that it is hard to believe that the legislature would have wanted it and one which is absurd in the sense that it falsifies or produces inconsistency in the legislation, so that even looking at nothing but the literal meaning of the text as a whole a difficulty emerges. A mere anomaly, however, is not in itself sufficient to prevent the application of the literal meaning of an Act. See, for example, the following passage of the judgment of Peter Gibson L.J. in Slamon v Planchon - "I share the judge's unease at a construction which gives rise to the two 'anomalies' which he has identified as arising, being circumstances in which a landlord is not a resident landlord for the purposes of the Leasehold Reform, Housing and Urban Development Act 1993, viz. (1) freehold held by a bare trustee for a beneficiary for part of the period between the date of conversion and the relevant date and by the beneficiary for the remainder of the period, and (2) freehold held by the trustee for A for life, remainder to A's son, for part of tha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to such uncertainty ... that it may provide a misleading rather than a reliable guide, and in any case affords a less certain guide than the construction of the words without a resort to conceptions of spirit and intention." The language used is not to be either stretched, in favour of the Crown or narrowed in favour of the taxpayer. So, where the court has to consider a provision expressly designed to prevent tax evasion, which uses unnecessarily wide language to achieve its purpose, that language will be given effect to even though the section is thereby made to apply to cases which it was probably never intended to catch. And where a statute referred to the surveyor of taxes "discovering" an undercharge, the House of Lords could "see no reason for saying that a discovery of undercharge can only arise where a new fact has been discovered. The words are apt to include any case in which for any reason it newly appears that the taxpayer has been undercharged." INTERPRETATION OF RULE 86A 53. At the outset, it would be apposite to refer to Rule 86A of the Rules, as the controversy in this batch of petitions centers around the interpretation of the said Rule. Rule 86A of the Rules i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... input tax available in the ECL has been fraudulently availed or is ineligible. If the said condition is satisfied, the officer may after recording the reasons in writing, not allow debit of an amount equivalent to such credit. The relevant portions of Rule 86A (1) of the Rules are highlighted below: "86A. Conditions of use of amount available in electronic credit ledger.- (1) The Commissioner or an officer authorised by him in this behalf, not below the rank of an Assistant Commissioner, having reasons to believe that credit of input tax available in the electronic credit ledger has been fraudulently availed or is ineligible in as much as- ** ** ** ** may, for reasons to be recorded in writing, not allow debit of an amount equivalent to such credit in electronic credit ledger for discharge of any liability under section 49 or for claim of any refund of any unutilised amount." 56. On a plain reading of the opening sentence of Rule 86A (1) of the Rules, the necessary conditions to be satisfied at the threshold are: (a) that there is a credit of input tax available in the Electronic Credit Ledger; and, (b) that the Commissioner or an officer authorized on his behalf has r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ust not be co-related to the ITC, which is credited in the ECL at the time of the decision to block a debit from the ECL. He submitted that the ITC, which is wrongfully availed (fraudulently availed or is ineligible) may have been available at another point of time but that would not preclude the Commissioner or an officer authorized by him, to issue an order under Rule 86A (1) of the Rules. However, the amount in respect of which debit is not allowed is confined to the quantum of the ITC, which the Commissioner has reasons to believe was fraudulently availed or is ineligible. He submits that this is a necessary construct of Rule 86A of the Rules as in most cases the reasons of fraudulent availment of the ITC or ineligible ITC would be available only after the same has been utilized by a taxpayer. The aforesaid contention was also articulated by other counsels. He also referred to a Circular (Circular No. CBEC-20/16/05/2021-GST) dated 02.11.2021 issued by the Central Board of Indirect Taxes and Customs (CBIC) and drew the attention of this Court of paragraphs 3.3.2 and 3.4.3 of the said Circular in support of the aforesaid contentions. 61. The aforesaid contentions are fashioned o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... onic credit ledger" plainly refers to the credit, which is at the given point of time available in the taxpayer's ECL. If the same had already been utilized in payment of tax, penalties or other dues, or has been refunded, the same would not be available in the ECL. 63. It is relevant to understand the meaning of the words, "availed", "available in the electronic credit ledger", "used" and "utilized" as used in the CGST Act and the Rules. 64. Section 41 of the CGST Act contains provisions regarding availment of ITC. It is relevant to refer to said Section at this stage and the same is set out below: "41. Availment of input tax credit.-(1) Every registered person shall, subject to such conditions and restrictions as may be prescribed, be entitled to avail the credit of eligible input tax, as self-assessed, in his return and such amount shall be credited to his electronic credit ledger. (2) The credit of input tax availed by a registered person under sub-section (1) in respect of such supplies of goods or services or both, the tax payable whereon has not been paid by the supplier, shall be reversed along with applicable interest, by the said person in such manner as may be pres ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Union territory tax, as the case may be, only after the input tax credit available on account of integrated tax has first been utilised fully towards such payment.] 49B. Order of utilisation of input tax credit.- Notwithstanding anything contained in this Chapter and subject to the provisions of clause (e) and clause (f) of sub-section (5) of section 49, the Government may, on the recommendations of the Council, prescribe the order and manner of utilisation of the input tax credit on account of integrated tax, central tax, State tax or Union territory tax, as the case may be, towards payment of any such tax." 68. Clearly, if ITC has been wrongly availed or utilized, the taxpayer is required to pay the said amount along with interest under Section 50(3) of the CGST Act as well as penalty leviable under the provisions of the CGST Act. 69. In view of the above, when Rule 86A (1) of the Rules refers to the ITC available in the ECL of a taxpayer (which the Commissioner or the officer authorized by him has reason to believe has been fraudulently availed or is ineligible), it clearly refers to the amount that is lying to the credit of the taxpayer in his ECL. It is difficult for us t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dulently availed or is ineligible, as per the conditions / grounds mentioned in sub-rule (1) of rule 86A. *** *** *** 3.4.3 As the restriction on behalf of electronic credit ledger under sub-rule (1) of rule 86A is resorted to protect the interests of the revenue and the said action also has bearing on the working capital of the registered person, it should be endeavored that in all such cases, the investigation and adjudication are completed at the earliest, well within the period of restriction, so that the due liability arising out of the same can be recovered from the said taxable person and the purpose of disallowing debit from electronic credit ledge is achieved." [Emphasis supplied] 73. We find that the aforesaid paragraphs of the Circular dated 02.11.2021 relied upon by the learned counsel for the Revenue do not support the contentions advanced by them. On the contrary, the same support the literal construct of Rule 86A of the Rules and also clarify that the amount of debit to be disallowed from the ECL should not be more than the amount of the ITC, which is believed to have been fraudulently availed or is ineligible. However, this would necessarily be subject to the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... any refund of any unutilised amount. b) Such restriction should be for an amount equivalent to the amount claimed to have been fraudulently availed or is ineligible 31. Rule 86A (1) of CGST Rules, 2017 is broadly divided into two parts. The opening part of the rule deals with the conditions required to be fulfilled in order to invoke the powers under the rule. The second part of the rule provides for the consequences in case Rule 86A is invoked. 32. In other words, in case the conditions prescribed for the invocation of Rule 86A are not fulfilled, the officer cannot invoke the rule, and in such scenario, the consequences provided in the rule becomes ex-facie inapplicable. 33. One of the primary conditions in order to invoke Rule 86A is that the Credit of input tax should be available in the electronic credit ledger. Further, such credit should be claimed to have been (supported by reason to believe recorded in writing) fraudulently availed. 34. Accordingly, in case where (i) Credit of input tax is not available in the electronic credit ledger or (ii) such credit has already been utilised, the powers conferred under Rule 86A cannot be invoked. 35. Further, Rule 86A is no ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... owing debit of an ITC is a temporary measure, which is imposed only if the conditions set out in Rule 86A of the Rules are satisfied. It is not necessary for any proceedings to be initiated against the taxpayer prior to passing an order under Rule 86A (1) of the Rules. The said order can be passed at any stage if the Commissioner or an officer authorized by him has reasons to believe that the credit available in the ECL of a taxpayer has been fraudulently availed or is ineligible. This is clearly an emergent provision, which enables the Commissioner to withhold the available ITC in the ECL, which he has reason to believe has been fraudulently availed or is ineligible. An order under Rule 86A (1) of the Rules does not require a prior show cause notice to be issued to a taxpayer as it is by its very nature an emergent provision to immediately block the usage of the ITC credited in the ECL, which the Commissioner or an officer authorized by him has reasons to believe has been fraudulently availed or is ineligible. The concerned authorities are required to proceed to determine whether a taxpayer has wrongly availed or utilized the ITC, under Sections 73 or 74 of the CGST Act and if it ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ire to accumulate to compensate for the ITC availed and utilized which the Commissioner or an officer authorized by him, has reasons to believe was fraudulently availed or was ineligible. CONCLUSION 83. In view of the above, the petitions are allowed and the orders impugned in the present petitions, as tabulated below, are set aside to the extent the impugned orders disallow debit from the respective ECL of the petitioners, in excess of the ITC available in the ECL at the time of passing of the impugned orders (referred to as Negative blocking by the counsel during the course of their submissions): Sl.No. Writ Petition Nos. Date of blocking of ECL Amount blocked (in Rs.) Negative blocked amount in ECL (in Rs.) 01 W.P.(C) No.10980/2024 26.07.2024 20,46,09,134.00 25,85,14,327.00 30.07.2024 6,82,83,894.00 02 W.P.(C) No.15380/2023 27.10.2023 1,62,88,226.00 1,62,88,226.00 03 W.P.(C) No.5250/2024 23.02.2024 1,71,64,374.00 1,71,52,374.00 04 W.P.(C) No.5395/2024 -- 4,55,27,380.00 4,44,89,152.00 05 W.P.(C) No.5397/2024 19.01.2024 16,01,760.00 3,83,72,654.00 21.03.2024 3,83,72,654.00 06 W.P.(C) No.6997/2024 11.03.2024 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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