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of The High Court addressed the issue of tax deduction at source for work contracts and supplies, and entitlement to Additional Tax Reimbursement u/s 64A of the Sale of Goods Act, 1930. To invoke Section 64A, two pre-conditions must be met: absence of a contrary contract and duty rate change post-contract. The court referenced MAFATLAL case on unjust enrichment. The case involved potential input tax credit benefits post-July 2017. Circular No. 3/2017-GST mandates GST payment at 6% u/s 12 and 13 of the Act of 2017 and CGST. Court upheld the 6% GST liability for invoices post-July 2017. The court couldn't determine Section 64A benefit due to insufficient evidence. Writ petition was disposed of.
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