Manual filing of Form ST-21 enabled for refund processing while the substantive pre-deposit refund issue remains open.

Manual filing of Form ST-21 is permitted where the online upload facility is unavailable, and the department is directed to process the refund within the specified timelines after receipt of the form. The Court expressly preserved the parties' rights and did not decide whether Form ST-21 is a mandatory precondition for refund of a pre-deposit, leaving that substantive issue open for determination. It also directed the respondents to file a counter-affidavit within four weeks and allowed a rejoinder within four weeks thereafter, regulating the conduct of the proceedings without adjudicating the merits.

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Outcome: The refund dispute was not finally adjudicated. The respondents were granted time to file a counter affidavit, and the petitioner was directed to furnish Form ST-21 and thereafter the refund claim was to be processed.

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