Telangana High Court Permits GST Dues in Instalments Via Manual DRC-20 Application

When a GST demand crystallises and the authorities simultaneously freeze your bank account by marking a lien, business liquidity can collapse almost overnight. The order of the High Court for the State of Telangana in VJK Enterprises Vs Superintendent (Writ Petition No.3920 of 2026) demonstrates how an assessee can seek instalment-based payment of GST dues and obtain relief from such constraints by invoking Form GST DRC-20, even where Rule 158 and system limitations appear to block the way.

This decision is particularly relevant for assessees who:

  • Have an admitted liability under GST
  • Have already paid a substantial part of the demand
  • Are facing attachment or lien on their bank accounts
  • Need structured instalments instead of a one-time lump-sum outflow

Factual Background of the Dispute

Origin of the Demand

An Order-in-Original dated 26.02.2025 was passed against M/s. VJK Enterprises, resulting in a GST demand comprising:

  • Tax
  • Interest
  • Penalty

Following the order:

  • On 16.04.2025, the assessee deposited Rs.5,33,128 through Form GST DRC-03.
  • As recorded in the judgment, this amount was stated to cover the tax portion and interest of Rs.1,680.

Despite this payment, the department proceeded to secure the balance dues by placing a lien on the assessee’s bank account.

Bank Lien and Disputed Amount

Respondent No.5 (the bank/authority concerned) marked a lien on the assessee’s bank account for Rs.8,92,644. This figure represented:

  • Tax
  • Interest
  • Penalty

under the same Order-in-Original dated 26.02.2025.

The assessee did not dispute the liability in principle but expressed an inability to discharge the entire remaining amount immediately in one go. Instead, the assessee:

  • Accepted the outstanding dues
  • Undertook before the Court to pay the balance in instalments

However, the assessee faced a procedural roadblock in attempting to obtain an instalment facility under Rule 158 of Central Goods and Services Tax Rules, 2017, particularly in the context of system/portal constraints and the lien already placed on the bank account.

Approach to the High Court

Confronted with an immediate liquidity crunch due to the bank lien, and the inability to clear the balance amount upfront, the assessee invoked the writ jurisdiction of the Telangana High Court seeking:

  • Permission to pay the outstanding demand in instalments
  • Corresponding relief from the existing lien on the bank account

The writ petition was heard by:

  • The Hon’ble Chief Justice Sri Aparesh Kumar Singh
  • The Hon’ble Sri Justice G.M. Mohiuddin

The central question was:

Whether, in the face of a GST demand and lien on bank account, an assessee can be permitted to discharge the remaining liability in instalments, and if so, what is the appropriate procedural route—particularly in light of Rule 158 of Central Goods and Services Tax Rules, 2017 and the requirement of Form GST DRC-20.

In essence, the Court examined:

  • The availability of instalment facility under the statutory framework
  • The manner in which an assessee should apply for such a facility
  • Whether a manual/physical application is permissible and effective where online processes or rules create practical hurdles

Stand of the Parties

Assessee’s Position

The assessee, M/s. VJK Enterprises, made the following key submissions: