As is where is basis: acceptance of declared lower-rate GST payments as full discharge, no refunds to higher-rate payers. The circular clarifies that where GST Council-directed regularisation on an 'as is' or 'as is, where is' basis addresses competing rates or interpretational doubt, the tax position declared in a taxpayer's returns at the lower or nil rate for the regularised period is treated as full discharge of liability, while taxpayers who paid the higher rate are not entitled to refunds; the regularisation does not protect taxpayers who paid no tax when the higher rate is held applicable, and applicable tax shall be recovered from nonpayers.