https://www.taxtmi.com/caselaws?id=150316 Article 226 may support consequential refund where the assessment or levy is also challenged, but a petition confined to refund is ordinarily not entertained. Refund cannot be directed while the underlying assessment orders remain in force; taxpayers must pursue a timely and proper challenge to those orders. Prolonged delay, failure to use statutory appellate remedies, and prima facie limitation concerns may justify refusal of discretionary writ relief. For mistake of law, the payer's actual state of mind at payment is decisive; an earlier judicial decision or discoverable legal position does not automatically negate the mistake. The petitions were declined because the assessments remained undisturbed and the challenges were brought too late through an improper route. en-us Wed, 02 May 1973 00:00:00 +0530 Mon, 13 May 2013 11:58:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=150316 Article 226 may support consequential refund where the assessment or levy is also challenged, but a petition confined to refund is ordinarily not entertained. Refund cannot be directed while the underlying assessment orders remain in force; taxpayers must pursue a timely and proper challenge to those orders. Prolonged delay, failure to use statutory appellate remedies, and prima facie limitation concerns may justify refusal of discretionary writ relief. For mistake of law, the payer's actual state of mind at payment is decisive; an earlier judicial decision or discoverable legal position does not automatically negate the mistake. The petitions were declined because the assessments remained undisturbed and the challenges were brought too late through an improper route. Case-Laws VAT and Sales Tax Wed, 02 May 1973 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=150316