GST recovery stay requires pre-deposit and undertaking; refund denied despite plea of ignorance of law

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....GST recovery stay pending Tribunal proceedings was available only on compliance with the prescribed pre-deposit and filing an undertaking to appeal within time; where the taxpayer did not follow that procedure and sought refund after recovery had already been made, refund was refused. The taxpayer's plea of ignorance of the circular was rejected on the principle that ignorance of law is no excuse. Granting refund would have operated as an impermissible waiver of the pre-deposit, while the Tribunal was left free to decide the appeal on merits.....