https://www.taxtmi.com/caselaws?id=783104 Service-tax amounts deposited during departmental investigation remain refundable where the Department later confirms that no tax liability existed. The six-month limitation in Section 102(3) of the Finance Act, 1994 does not defeat restitution in these circumstances, because the deposit was not made under an assessment or adjudicated liability and was retained without legal authority. Article 265 of the Constitution prevents collection or retention of tax not authorised by law. A refund application filed promptly after closure of the investigation therefore supports repayment of the deposit with applicable interest. en-us Fri, 05 Dec 2025 00:00:00 +0530 Mon, 24 Aug 2026 10:48:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783104 Service-tax amounts deposited during departmental investigation remain refundable where the Department later confirms that no tax liability existed. The six-month limitation in Section 102(3) of the Finance Act, 1994 does not defeat restitution in these circumstances, because the deposit was not made under an assessment or adjudicated liability and was retained without legal authority. Article 265 of the Constitution prevents collection or retention of tax not authorised by law. A refund application filed promptly after closure of the investigation therefore supports repayment of the deposit with applicable interest. Case-Laws Service Tax Fri, 05 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783104