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    <title>2026 (10) TMI 367 - GSTAT RAIPUR</title>
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    <description>Before 10 July 2024, credit of funds to the Electronic Cash Ledger did not constitute payment of self-assessed return tax; payment occurred only when the appropriate electronic ledger was debited. Interest on the cash component therefore continued until debit, despite receipt of funds through the Government banking channel. The Rule 88B(1) proviso excluding continuously retained cash-ledger balances applies prospectively because it contains no retrospective commencement provision. Notice validity requires demonstrated prejudice; detailed responses based on communicated interest calculations negate such prejudice. Although a requested personal hearing is required before an adverse decision, remand is unnecessary where facts and the sole statutory issue are undisputed and no further defence or evidence is identified. Reconciliation is required to prevent double recovery.</description>
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      <description>Before 10 July 2024, credit of funds to the Electronic Cash Ledger did not constitute payment of self-assessed return tax; payment occurred only when the appropriate electronic ledger was debited. Interest on the cash component therefore continued until debit, despite receipt of funds through the Government banking channel. The Rule 88B(1) proviso excluding continuously retained cash-ledger balances applies prospectively because it contains no retrospective commencement provision. Notice validity requires demonstrated prejudice; detailed responses based on communicated interest calculations negate such prejudice. Although a requested personal hearing is required before an adverse decision, remand is unnecessary where facts and the sole statutory issue are undisputed and no further defence or evidence is identified. Reconciliation is required to prevent double recovery.</description>
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