Delayed IGST refund attracts statutory interest once the refund claim is final and unpaid beyond the prescribed period.

Interest is payable on delayed IGST refund arising from export shipments where the refund had attained finality but was released only after the statutory period. On a conjoint reading of Sections 54 and 56 of the CGST Act, once a refundable tax amount is not paid within sixty days from the refund application, interest follows for the period of delay. Administrative or verification-related delays do not displace the statutory obligation. The refund claim was treated as arising from the shipping bills, and the balance refund having been released during the writ proceedings, the court held that interest remained payable on the delayed refund.

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Issues: Entitlement to interest on delayed refund of IGST arising from export shipments after the refund was ultimately released.

Analysis: The refund claim arose from export of goods under shipping bills and was ultimately crystallised after the adjudicatory and appellate proceedings attained finality. On a conjoint reading of Section 54 and Section 56 of the CGST Act, delayed refund of tax ordered to be refunded attracts interest once the refund is not made within sixty days from the date of the refund application. The refund application here was treated as arising from the shipping bills, and the balance IGST refund was admittedly released only during the pendency of the petition. The Department's stand that interest was not payable because of administrative or verification issues was held to be inconsistent with the statutory scheme governing delayed refunds.

Conclusion: Interest on the delayed IGST refund was payable, and the petitioner succeeded on this issue.

Ratio Decidendi: Where a tax refund becomes payable and is not released within the statutory period, Section 56 of the CGST Act mandates payment of interest for the period of delay, regardless of internal administrative delays once the refund claim has attained finality.

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