Section 11B Inapplicable for Tax Refunds if Services Aren't Taxable Under 1994 Act; No Unjust Enrichment Allowed.

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....Refund of tax - the department cannot get itself unjust enriched by relying on Section 11B of the Act. If the services are not coming within the ambit of taxable service as contemplated under the Act 1994, Section 11B of the Act is not applicable.....