https://www.taxtmi.com/caselaws?id=385404 Interest on refund arising under Section 54(1)(aa) of the Gujarat Sales Tax Act, 1969 is a distinct substantive entitlement, and the third proviso to Section 54, which is framed for refunds under clauses (a) and (b), cannot be extended to restrict that entitlement. Applying the settled rule that a proviso must remain confined to the subject matter of the enacting clause, the period during which appeals were pending could not be excluded by relying on that proviso. The interest computation excluding that litigation period was therefore legally untenable, and the correct interest position had to be determined afresh. en-us Wed, 28 Aug 2019 00:00:00 +0530 Sat, 07 Mar 2020 10:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=385404 Interest on refund arising under Section 54(1)(aa) of the Gujarat Sales Tax Act, 1969 is a distinct substantive entitlement, and the third proviso to Section 54, which is framed for refunds under clauses (a) and (b), cannot be extended to restrict that entitlement. Applying the settled rule that a proviso must remain confined to the subject matter of the enacting clause, the period during which appeals were pending could not be excluded by relying on that proviso. The interest computation excluding that litigation period was therefore legally untenable, and the correct interest position had to be determined afresh. Case-Laws VAT and Sales Tax Wed, 28 Aug 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=385404