GST statutory scheme cannot be overridden by reimbursement disputes; revised returns and waiver directions against tax authorities were set aside.

A reimbursement dispute under a works contract was treated as distinct from the statutory GST regime. The text states that liability for GST must be determined strictly under the governing tax enactments, and courts cannot direct filing of revised GST returns or grant a blanket waiver of interest, penalty or limitation contrary to statute. It further states that, where the controversy is confined to reimbursement between contractors and the employer, no directions can be issued to tax authorities on levy, assessment, recovery or collection of tax. The impugned directions against the State and tax authorities were set aside, while the reimbursement issue remained confined to the employer-contractor relationship.

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Issues: Whether directions could be sustained permitting filing of revised GST returns, waiver of interest, penalty and limitation, and whether the tax authorities could be directed to reimburse the incremental GST paid by the contractors.

Analysis: The dispute as to reimbursement of incremental GST was held to be one between the contractors and their employers and did not alter the statutory scheme governing levy, assessment, recovery and enforcement of GST. The liability to pay GST had to be determined strictly in accordance with the relevant tax enactments, and no directions could be issued contrary to the statute permitting revised returns or granting blanket waiver of interest, penalty or limitation. Since the controversy before the Court was confined to reimbursement, no directions could be issued to the tax authorities on levy, assessment or collection of tax.

Conclusion: The directions against the State and tax authorities were set aside, and the reimbursement direction was confined to the concerned employer only.

Final Conclusion: The appeal succeeded to the extent that the impugned order could not operate against the tax authorities or the State, though the reimbursement issue remained a matter between the contractors and the employer.

Ratio Decidendi: A court cannot issue directions affecting GST returns, waiver of statutory consequences, or tax administration contrary to the governing fiscal statute, and a reimbursement dispute under a works contract does not authorise directions to the tax authorities on levy or collection.

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