GST reimbursement in works contracts remains contractual, while statutory return, limitation and penalty relief cannot be ordered.

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....Under works contracts, reimbursement of incremental tax is treated as a contractual issue between contractor and employer, while GST levy, assessment, recovery and enforcement remain governed strictly by the statute. No judicial direction can permit filing revised returns contrary to the GST framework or waive limitation, interest or penalty outside the Act. On that basis, the High Court found the reimbursement direction unsustainable and limited relief to directing consideration of the representations in accordance with law, modifying the single judge's order accordingly.....