Refund conditions must follow appellate directions: solvent security cannot be replaced by a bank guarantee.

Refund authorities could not insist on a bank guarantee where the appellate order required only solvent security under the Rajasthan GST Act. Solvent security and bank guarantee are distinct conditions, and the authority was bound to implement the earlier direction without adding a new requirement. The demand for bank guarantee was therefore inconsistent with the appellate order and could not be used to obstruct processing of the refund application. The petitioner was entitled to refund in accordance with the original directions.

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Issues: Whether the refund authorities could insist on a bank guarantee when the appellate authority had required only solvent security under Section 54(11) of the Rajasthan Goods and Services Tax Act, 2017.

Analysis: The appellate authority had directed processing of the refund application on the petitioner furnishing solvent security. The subsequent insistence on a bank guarantee was held to be inconsistent with that direction. Solvent security and bank guarantee were treated as distinct concepts, and the authority could not expand the condition imposed for release of refund by substituting one for the other. The demand for bank guarantee was found to be an attempt to block implementation of the refund directions.

Conclusion: The demand for bank guarantee was unsustainable and the petitioner was entitled to refund in accordance with the earlier directions.

Final Conclusion: The refund authorities were bound to act within the limits of the appellate order and could not impose an additional condition not contemplated by it.

Ratio Decidendi: A refund authority cannot substitute a bank guarantee for solvent security when the governing order permits refund upon furnishing solvent security, as the two are not legally equivalent.

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