2025 (8) TMI 1711

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....: Mr. Aakarsh Srivastava, SSC with Mr. Anand Pandey, Adv. ORDER 1. This hearing has been done through hybrid mode. CM APPL. 49943/2025 (for exemption) 2. Allowed, subject to all just exceptions. Application is disposed of. W.P.(C) 12251/2025 3. The present petition has been filed challenging the impugned order dated 25th February, 2025 passed under Section 54(11) of the Central G....

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....inion under Section 54(11)cannot be relied upon on a standalone basis. In the absence of an appeal or any other proceeding pending, challenging the order of the Appellate Authority, the opinion under Section 54(11) cannot result in holding back the refund. The refund having been permitted by the Appellate Authority and no order in review having been passed, the Department cannot hold back the refu....