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    <title>2025 (11) TMI 1419 - KARNATAKA HIGH COURT</title>
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    <description>HC held that tax wrongly paid as IGST to Central authorities, when the transaction was later treated as intra-State and tax was paid again to State authorities, must be refunded. Relying on Lenovo and Nspira, HC held Section 54 CGST Act and Rule 89(1A) CGST Rules to be directory, not mandatory, and that limitation could not defeat a legitimate refund, especially in view of Article 265 and principles of restitution and unjust enrichment. The rejection of refund as time-barred was set aside. HC held the refund claim within time and remanded the matter to the adjudicating authority to decide the refund on merits within a stipulated period.</description>
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      <link>https://www.taxtmi.com/caselaws?id=781951</link>
      <description>HC held that tax wrongly paid as IGST to Central authorities, when the transaction was later treated as intra-State and tax was paid again to State authorities, must be refunded. Relying on Lenovo and Nspira, HC held Section 54 CGST Act and Rule 89(1A) CGST Rules to be directory, not mandatory, and that limitation could not defeat a legitimate refund, especially in view of Article 265 and principles of restitution and unjust enrichment. The rejection of refund as time-barred was set aside. HC held the refund claim within time and remanded the matter to the adjudicating authority to decide the refund on merits within a stipulated period.</description>
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