https://www.taxtmi.com/caselaws?id=796367 Service tax on manpower supply services was payable entirely by the recipient under reverse charge from 1 April 2015, leaving the service provider not liable to collect or deposit the tax. Where the Department retained tax deposited by the provider and also recovered tax on the same services from the recipient, retention of the duplicate collection amounted to unjust enrichment. The provider's delayed awareness, arising only on receipt of the recipient's debit note, constituted exceptional circumstances in which statutory limitation could not defeat restitution. A refund of the wrongly retained amount was therefore available despite limitation and notwithstanding an appellate remedy. en-us Wed, 29 Jul 2026 00:00:00 +0530 Wed, 05 Aug 2026 08:48:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796367 Service tax on manpower supply services was payable entirely by the recipient under reverse charge from 1 April 2015, leaving the service provider not liable to collect or deposit the tax. Where the Department retained tax deposited by the provider and also recovered tax on the same services from the recipient, retention of the duplicate collection amounted to unjust enrichment. The provider's delayed awareness, arising only on receipt of the recipient's debit note, constituted exceptional circumstances in which statutory limitation could not defeat restitution. A refund of the wrongly retained amount was therefore available despite limitation and notwithstanding an appellate remedy. Case-Laws Service Tax Wed, 29 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796367