Retrospective operation of the substituted proviso to section 50(1) confines GST interest on delayed tax payment to the tax discharged through the electronic cash ledger, excluding the component paid by utilising input tax credit. Refund claims for interest paid on the credit-ledger component require verification of statutory conditions, payment and eligible quantum. Refund limitation cannot be introduced as a decisive appellate ground without notice and an effective opportunity to address the relevant date, computation and applicable exclusions. Limitation must be recomputed under section 54 after applying the notified exclusion of the specified COVID-19 period, followed by a hearing and consequential determination.
Retrospective operation of the substituted proviso to section 50(1) confines GST interest on delayed tax payment to the tax discharged through the electronic cash ledger, excluding the component paid by utilising input tax credit. Refund claims for interest paid on the credit-ledger component require verification of statutory conditions, payment and eligible quantum. Refund limitation cannot be introduced as a decisive appellate ground without notice and an effective opportunity to address the relevant date, computation and applicable exclusions. Limitation must be recomputed under section 54 after applying the notified exclusion of the specified COVID-19 period, followed by a hearing and consequential determination.
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TaxTMI 
TaxTMI 
of 4910 
