https://www.taxtmi.com/caselaws?id=45900 A prospective declaration of invalidity of vend fee meant the State could retain sums already realised before the cut-off date, including amounts deposited under interim orders, but it could not make any fresh recovery for unpaid amounts after that date because there was no valid authority to collect the levy. The distinction was drawn between actual realisation and mere security: a bank guarantee was not payment and could not be encashed to satisfy a levy the State was no longer entitled to enforce. Article 265 barred collection without authority of law, while Article 142 supported moulding relief to preserve past realisations. en-us Tue, 17 Apr 2001 00:00:00 +0530 Wed, 17 Dec 2025 11:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=45900 A prospective declaration of invalidity of vend fee meant the State could retain sums already realised before the cut-off date, including amounts deposited under interim orders, but it could not make any fresh recovery for unpaid amounts after that date because there was no valid authority to collect the levy. The distinction was drawn between actual realisation and mere security: a bank guarantee was not payment and could not be encashed to satisfy a levy the State was no longer entitled to enforce. Article 265 barred collection without authority of law, while Article 142 supported moulding relief to preserve past realisations. Case-Laws Central Excise Tue, 17 Apr 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=45900