Service Tax Refunds During Investigation Are Deposits, Not Payments; Unjust Enrichment Principles Don't Apply.

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....Refund of Service Tax paid - unjust enrichment - any amount deposited during the pendency of adjudication or investigation is in the nature of a deposit and, therefore, cannot be considered to be towards payment of service tax or excise duty. The principles of unjust enrichment, therefore, would not apply if a refund is claimed for refund of this amount. - AT....