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    <description>Refund of tax collected under a levy later declared unconstitutional is treated as a restitutionary claim, so the ordinary limitation and restrictive refund conditions under Section 54 of the Andhra Pradesh GST Act do not control entitlement to return of the amount. Interest is compensatory for loss of use of money, and where tax was paid under an unconstitutional levy, interest is payable for the entire period from deposit until refund. The rate was treated as fair and equitable by reference to the statutory benchmark, supporting interest on the refunded sum rather than denial on limitation grounds.</description>
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