TMI Blog2022 (2) TMI 934X X X X Extracts X X X X X X X X Extracts X X X X ..... d of ITC and the case of refund on account of inverted duty structure under sub-Section 3 and Section 54 inter alia dealing with credit accumulation on account of rate of tax on inputs being higher than the rate of tax on output supplies. The Hon ble Supreme Court ultimately held that refund is statutory right and the extension of the benefit of refund only to the unutilised credit that accumulates on account of rate of tax on input goods being higher than the rate of tax on output supplies, by excluding unutilised input tax credit that accumulated on account of input services, is a valid classification and a valid exercise of legislative power. Though in the instant case we are not dealing with section 54 of CGST Act but are concerned with transitional provisions dealing with refund under section 142(3) of the CGST Act in cash under certain circumstances in connection with taxes suffered under the previous regime. However, the fundamental concepts and the interpretation of law relating to refund would still be the same and what is to be seen is whether the petitioner qualifies for entitlement of refund under section 142(3) of CGST Act in the light of the facts and circumsta ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... governs refund as an assessee cannot be permitted to have transitional credit as well as refund of the same tax amount. It is apparent from the impugned orders that the specific case of the respondent is that the petitioner had claimed CENVAT Credit under ST-3 return thereby treating the services involved in the present case as their input services used for providing output service, whereas they are not output service provider and the same cannot be used for providing output services. Therefore, it cannot be their input services under Rule 2 (l) of CENVAT Credit Rules, 2004 - the authority has rightly held that petitioner had wrongly claimed Credit of the impugned service tax under ST-3 return and omitted to claim the impugned service tax as CENVAT Credit in ER-1 Return. The authorities have held in the impugned orders that in the instance case, the timeline for claiming CENVAT Credit qua the service tax paid on port services was not followed by the petitioner, although the services were availed, the entire payment was made and the bill was also generated in the month of April/May, 2017. Further, it has also been held in the impugned orders that the petitioner not only faile ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... CENVAT Credit Rules, 2004. 4. The following are the foundational facts for filing of the present writ petition: - Date Events period 26.04.2017 to 29.04.2017 The petitioner was registered under Central Excise Act, 1944 for manufacture of excisable goods in which the inputs Iron Ore, Coal, Dolomite etc. are used. The petitioner used to procure input i.e. coal, domestically as well as from outside the territory of India and for importing coal, the petitioner availed input services such as Port Services . period 26.04.2017 to 29.04.2017 At the relevant point of time, the petitioner was also registered under Chapter V of the Finance Act, 1994 as a person liable to pay tax on receipt of taxable services under reverse charge mechanism as a recipient of Goods Transport Agency Services . period 26.04.2017 to 29.04.2017 The dispute relates to the period 26.04.2017 to 29.04.2017, when the petitioner imported 23000 MT of Coal from outside the territory of India through Haldia Port under Bill of Entry dated 27.04.2017 for u ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... uty paying documents/bills were already received by the petitioner except credit of aforesaid amount of ₹ 10,88,328/- as the bill dated 23.05.2017 in original was not yet received by the petitioner. 20.09.2017 The original of the bill dated 23.05.2017 was delivered to the petitioner only on 20.09.2017 and it is the specific case of the petitioner that such delay was beyond their control. 22.09.2017 on 22.09.2017 the petitioner filed their ST-3 return for the period April, 2017 to June, 2017 under Chapter V of the Finance Act, 1994 taking all service invoices where they were liable to pay service tax under reverse charge basis. Further it is the case of the petitioner that in the said ST-3 return the petitioner disclosed the said Input Service Credit on port services amounting to ₹ 10,88,328/- with a view to keep the said transaction above the board so that their claim is not lost. 31.10.2017 The time for filing TRAN-1 for claiming transitional credit was extended till 31.10.2017 vide notification issued by Central Board of Direct Taxe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t of claiming the credit in the ER-1 returns for the month of June, 2017 for obvious reasons that by the time invoices are received the limitation for filing ER-1 would have expired. Hence, in such case mere disclosure of the receipt of services in the books of accounts is enough. Section 141 of CGST Act deals with the transitional provision relating to job work which is not relevant in the present case. It is the specific case of the petitioner that Section 142 of CGST Act deals with miscellaneous transitional provisions which are not covered under Section 140 or Section 141 of the CGST Act. The case of the petitioner is covered under Section 142 (3) of the CGST Act which is the substantive provision which allows refund of CENVAT Credit in certain contingencies as transitional measures. ii) Sub-Section 3 of Section 142 of the CGST Act, inter alia provides for refund of CENVAT Credit in cash accruing to the assessee under the CENVAT Credit Rules. The provisions of Section 142 are residuary substantive provisions which deal with refund of CENVAT Credit in cases/contingencies which are not specifically covered or contemplated under Section 140 of the Central Goods Services Tax ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 42 (3) is a substantive provision, which deals with refund of CENVAT Credit in special circumstances like the present case, where the original invoice dated 23.05.2017 was received by the petitioner on 20.09.2017 i.e., after coming into force of GST Act. ix) It is submitted by the petitioner that the CENVAT Credit of said amount of service tax paid on port service earned lawfully under the existing laws which is a substantive benefit conferred by and earned under the existing law which cannot be defeated or taken away without authority of law contrary to mandates of Article 14, Article 19 (1) (g), Article 265 and Article 300A of the Constitution of India. x) The respondent authorities erred in law while holding that there is no provision of law granting refund of tax paid on input services under Section 11 B of Central Excise Act relatable to the facts and circumstances of this case. xi) The legislature was well aware of the fact that during the transitional period, there might be situations which might not be covered under Section 140 of the CGST Act and such claims are required to be refunded in cash and therefore, saved Section 11B (2) of the Central Excise Act an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s reported in (1999) 2 SCC 361 to submit that rights accrued under existing law not to be altered. i) Commissioner of Central Excise, Indore Vs Grasim Industries Ltd. through its Secretary reported in (2018) 7 SCC 233 to submit that excise duty / CENVAT is value added tax. j) Kunal Kumar Tiwari Alias Kunal Kumar Vs. State of Bihar and Another reported in (2018) 16 SCC 74 to submit that an interpretation which advances the purpose or object underlying the Act should be preferred. k) M/s DMR Constructions Vs. Assistant Commissioner, Commercial Tax Department, Rasipuram Namakkal District , a judgement passed by Hon ble Madras High Court reported in 2021- TIOL-831-HC-MAD-GST to submit that considering the purposive construction, the Hon ble Madras High Court has granted transition of credit of tax deducted at source under VAT law even when Section 140 of Tamil Nadu GST Act, 2017 does not specifically provide for it. l) Glaxo Smith Kline PLC and others Vs. Controller of Patents and Designs and Others reported in (2008) 17 SCC 416 to submit that pre-existing right prior to coming into force of the new law continues to be governed by the old law and their right ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ement for input tax credit and the board also clarified certain transitional issues of similar nature vide Circular dated 28.09.2017 under which also, the case of the petitioner is not covered. Section 142 (3) of CGST Act has no applicability. The petitioner was rightly served show cause notice denying the refund of CENVAT Credit of input service under Section 142 read with Section 174 of CGST Act, 2017 read with Section 11 B of Central Excise Act, 1944 as made applicable under Section 83 of Chapter V of the Finance Act, 1994. The petitioner failed to incorporate the CENVAT Credit in ER- 1 return in time and consequently, was not eligible to claim the said credit through TRAN 1 under Section 140 of CGST Act, 2017 read with Rule 117 of CGST Rules. He submits that the petitioner was entitled to CENVAT Credit had he claimed the same in time by reflecting it in monthly return ER-1 and then through TRAN 1 and there is no other mechanism to claim input tax credit other than TRAN- 1. It is further submitted that the petitioner had illegally taken credit of the impugned amount of service tax in ST-3 return though the petitioner was not an output service provider and was registered un ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s become the property of the Union/States; (ii) The refund of taxes is neither a fundamental right nor a constitutional right. The Constitution only guarantees that the levy should be legal and that the collection should be in accordance with law. There is no constitutional right to refund. Refund is always a matter of a statutory prescription and can be regulated by the statute subject to conditions and limitations; (iii) Even in the case of an illegal levy or a levy which is unconstitutional, the decision of the nine judges Bench in Mafatlal Industries Limited v. Union of India held that the right of refund is not automatic. The burden of proof lies on the claimant to establish that it would not cause unjust enrichment; (iv) Though tax enactments are subject to Articles 14 and 19(1)(g) of the Constitution, this is subject to two well-settled principles: (a) Discriminatory treatment under tax laws is not per se invalid. It is invalid only when equals are treated unequally or unequals are treated equally. Both under the Constitution and the CGST Act, goods, services, input (goods) and input services are not one and the same. These are distinct species, t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on output supplies, Parliament has confined the refund in the manner which we have described above. While recognising an entitlement to refund, it is open to the legislature to define the circumstances in which a refund can be claimed. The proviso to Section 54(3) is not a condition of eligibility (as the assessees Counsel submitted) but a restriction which must govern the grant of refund under Section 54(3). We therefore, accept the submission which has been urged by Mr. N Venkataraman, learned ASG. 93. Parliament engrafted a provision for refund Section 54(3). In enacting such a provision, Parliament is entitled to make policy choices and adopt appropriate classifications, given the latitude which our constitutional jurisprudence allows it in matters involving tax legislation and to provide for exemptions, concessions and benefits on terms, as it considers appropriate. The consistent line of precedent of this Court emphasises certain basic precepts which govern both judicial review and judicial interpretation of tax legislation. These precepts are .. 94. The principles governing a benefit, by way of a refund of tax paid, may well be construed on an analogous fram ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... und would still be the same and what is to be seen is whether the petitioner qualifies for entitlement of refund under section 142(3) of CGST Act in the light of the facts and circumstances of this case. Legal proposition on the point of interpretation of transitional provisions, vested rights etc with reference to the judgements relied upon by the learned counsel of the petitioner. 10. The learned counsel for the petitioner has also referred to the judgment passed in the case of Union of India vs. Filip Tiago De Gama of Vedam De Gama (supra) on the point that the transitional provisions are to be purposefully construed and the paramount object in statutory interpretation is to discover what the legislature intended and this intention is primarily to be ascertained from the text of the enactment in question. This principle of statutory interpretation is well settled. 11. So far as the case of K. S. Paripoornan (supra) is concerned, the Hon ble Supreme Court has considered the role of Transitional Provision and the learned counsel for the petitioner has referred to Para-71 of the said judgment, which is quoted as under: - 71. Section 30 of the amending Ac ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s rule of construction that in cases of conflict between a specific provision and a general provision the specific provision prevails over the general provision and the general provision applies only to such cases which are not covered by the specific provision, we must hold that Cl. 5(a) has no application in a case where the special provisions of Cl. 23 are applicable. The aforesaid judgment does not help the petitioner in any manner in view of the fact that there is no conflict amongst the various provisions of CGST Act referred to by the learned counsel for the petitioner during the course of argument, particularly with reference to Sections 140, 142 and 174 of the CGST Act. The provisions have been interpreted in later portion of this judgement. 14. The learned counsel has further referred to the judgment in the case of CIT vs. J. H. Gotla reported in (1985) 4 SCC 343 to submit that even in taxation, if strict literal construction leads to absurdity, construction which results in equity rather than injustice, should be preferred. However, during the course of argument, the learned counsel has failed to demonstrate as to how any of the provisions of CGST Act which h ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ing right of a party has to be determined on the basis of the statute which was applicable and not under the new one. If a new Act confers a right, it does so with prospective effect when it comes into force, unless expressly stated otherwise. 17. In the case of Glaxo Smith Kline PLC and Others (supra), the Hon ble Supreme Court has upheld the view of the learned single judge of the High Court and held at Para-17 as under: - 17. The learned Single Judge s view that the provisions of Section 78 of the Amendment Act have no application to the proceedings which stood concluded before the appointed day appears to be the correct view governing the issue. Since Chapter IV-A in question was merely repealed, the situation has to be dealt with in line with Section 6 of the General Clauses Act. The provisions of Section 78 are conditional provisions and are not intended to cover cases where the application for EMR had been rejected with reference to Section 21 of the amending enactment. As noted above, Chapter IV-A was repealed. The effect of the repeal has to be ascertained in the background of Section 6 of the General Clauses Act. That being so, the order of the Division Benc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ent made complete. Any manner or mode of application of the said Rule would result in affecting the rights of the assessees. 6. We may look at the matter from another angle. If on the inputs, the assessee had already paid the taxes on the basis that when the goods are utilised in the manufacture of further products as inputs thereto then the tax on these goods gets adjusted which are finished subsequently. Thus, a right accrued to the assessee on the date when they paid the tax on the raw materials or the inputs and that right would continue until the facility available thereto gets worked out or until those goods existed. Therefore, it becomes clear that Section 37 of the Act does not enable the authorities concerned to make a rule which is impugned herein and, therefore, we may have no hesitation to hold that the Rule cannot be applied to the goods manufactured prior to 16-3-1995 on which duty had been paid and credit facility thereto has been availed of for the purpose of manufacture of further goods. 19. The learned counsel has also referred to the judgment passed in the case of CCE vs. Grasim Industries Ltd. (supra) to submit that excise duty/CENVAT is value adde ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... it of the impugned service tax in ST-3 return and thereafter claimed refund of the same by referring to section 142(3) of CGST, Act. Accordingly, the said judgement does not apply to the facts and circumstances of this case. The sequence of facts; case of the parties and the contents of the impugned orders 24. The petitioner was having Central Excise Registration for manufacture of sponge iron, billet and TMT Bar. The petitioner was also registered under Service tax only as a person liable to pay service tax under Reverse Charge Mechanism. Admittedly, the port services involved in this case is not covered under Reverse Charge Mechanism and therefore the same was not includable in the service tax return filed by the petitioner under ST-3. Accordingly, the petitioner was not entitled to avail credit of the impugned service tax paid on the port services in its service tax ST-3 return. 25. It is not in dispute that the petitioner was entitled to claim CENVAT Credit on the service tax paid on port services if used in the manufacturing activity for which the petitioner was registered under the Central Excise Act, 1944. 26. The petitioner had imported coal th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... paid on port services in their service tax return ST-3 as the petitioner was not an output service provider and was liable to file service tax return and pay service tax only under reverse charge mechanism. Admittedly, port services were not under reverse charge mechanism. 29. Further, Rule 5 of CENVAT Credit Rules, 2004 permits refund only when the services are used to export goods or services, which is not the case in the present case. It is not the case of the petitioner that the impugned services were used for export of goods or services. Thus, under the existing law the claim of refund of service tax paid by the petitioner on port services was not admissible. 30. The case of the petitioner is that since they received the original copy of the Bill dated 23.05.2017 as late as on 20.09.2017, they could not take CENVAT Credit in their last ER-1 return for June, 2017 filed on 30.07.2017. However, the petitioner took the credit of ₹ 10,88,328/- in their ST-3 return for April-June, 2017 filed on 22.09.2017 with a view to keep the said transaction above board so that their claim was not lost. It is also not in dispute that the last date for filing TRAN-1 was extend ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is beneficial piece of legislation and should be construed liberally; (ii) The said services are used for procurement of inputs are amply covered in the definition of input service in terms of Rule 2(l) of CCR, 2004 and disclosure or non-disclosure of said credit in ST-3 and/or ER-1 are irrelevant. (iii) Ultimate eligibility of the credit of the impugned services is not in dispute and the benefit of CENVAT Credit eventually accrues to them which is the heart and soul of Section 142(3) of the CGST Act, 2017 and under Section 142(3) there is no statutory precondition that in order to claim the transitional credit, the claim must be disclosed in the ER-1 return; (iv) Section 142(3) of the CGST Act, 2017 provides for refund of CENVAT Credit in cash accruing to the assessee under CENVAT Credit Rules, 2004. Section 142 is a residuary provision which deals with cases/contingencies which are not specifically covered or contemplated under Section 140 or 141. Since, in the instant case the provision of Section 140(5) or any other sub-Section does not cover the contingencies as in the present case, it would be covered by the residuary provision of Section 142(3); (v) Se ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ceived the invoice on 20.09.2017 and they made provisional entry in their books of account. They could not take credit in their last ER-1 return for June, 2017 which they filed on 30.07.2017 for the reason beyond their control. They could not have filed any return thereafter when Central Excise Act, 1944 and the rules made thereunder was repealed; ii. They could not avail the benefit of Section 140(5) of the CGST Act, 2017 for the same reason that the original copy of the invoice was received in September, 2017. They were left with no option than to file refund Application vide their letter dated 29.06.2018 under residuary provision of Section 142(3) read with Section 174(2)(c) of the CGST Act and Section 11B(2)(c) of the Central Excise Act, 1944; iii. There is no requirement under Section 142(3) of the CGST Act of disclosure of the CENVAT Credit in the ER-1 return like Section 140(5) and unlike Section 140(1). 38. The appellate authority rejected the appeal with the following findings: a. The transitional provisions contained in Section 140 of the CGST Act, 2017 provide for carrying forward of closing balance of the amount lying in CENVAT Credit account as refl ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eguards, conditions and limitation as may be specified by the Central Government by a notification. f. The appellate authority referred to a judgement passed by the North Zonal Bench of the CESTAT in the case of Purvi Fabrics Texturise (P) Ltd. v. Commissioner of Central Excise, Jaipur-II - 2004 (172) E.L.T. 321 (Tri.- Del.), wherein it was held that there is no legal provision existing for refund either by cash or cheque. The only exception carved out is that the refund in cash is granted as an incentive measure to the exporter. The provisions and particularly Section 11B of the Central Excise Act provides for payment of amount of refund to the applicant only in situations specified in proviso to sub-section (2) of Section 11B of the Central Excise Act, 1944. The appellate authority held that the petitioner has attempted to claim something which the law does not permit at all. g. The appellate authority also held that the claim of refund is not a matter of right unless vested by law. The plea of injustice or hardship cannot be raised to claim refund in the absence of statutory mandate. In this regard, a reference was made to the judgment of the Hon ble Supreme Court se ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... a vis the facts of this case. 39. The relevant portions of the aforesaid sections as relied upon by the learned counsel for the petitioner during the course of arguments are as under. Section 140 (1) and (5) of the CGST, Act reads as under:- 140. (1) A registered person, other than a person opting to pay tax under section 10, shall be entitled to take, in his electronic credit ledger, the amount of CENVAT Credit of eligible duties carried forward in the return relating to the period ending with the day immediately preceding the appointed day, furnished by him under the existing law within such time and in such manner as may be prescribed: PROVIDED that the registered person shall not be allowed to take credit in the following circumstances, namely: - (i) where the said amount of credit is not admissible as input tax credit under this Act; or (ii) where he has not furnished all the returns required under the existing law for the period of six months immediately preceding the appointed date; or (iii) where the said amount of credit relates to goods manufactured and cleared under such exemption notifications as are notified by the Gove ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 955), the Additional Duties of Excise (Goods of Special Importance) Act, 1957 (58 of 1957), the Additional Duties of Excise (Textiles and Textile Articles) Act, 1978 (40 of 1978), and the Central Excise Tariff Act, 1985 (5 of 1986) (hereafter referred to as the repealed Acts) are hereby repealed. (2) The repeal of the said Acts and the amendment of the Finance Act, 1994 (32 of 1994) (hereafter referred to as such amendment or amended Act , as the case may be) to the extent mentioned in the sub-section (1) or section 173 shall not- (a) revive anything not in force or existing at the time of such amendment or repeal; or (b) affect the previous operation of the amended Act or repealed Acts and orders or anything duly done or suffered thereunder; or (c) affect any right, privilege, obligation, or liability acquired, accrued or incurred under the amended Act or repealed Acts or orders under such repealed or amended Acts: PROVIDED that any tax exemption granted as an incentive against investment through a notification shall not continue as privilege if the said notification is rescinded on or after the appointed day; or (d) affect any duty, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... efunded in cash, notwithstanding anything to the contrary contained under the provisions of existing law other than the provisions of sub-section (2) of section 11-B of the Central Excise Act, 1944. e. It also provides that where any claim for refund of CENVAT Credit is fully or even partially rejected, the amount so rejected shall lapse. f. The second proviso provides that no refund shall be allowed of any amount of CENVAT Credit where the balance of the said amount as on the appointed day has been carried forward under the CGST Act. 41. Thus, section 142(3) of CGST, Act clearly provides that refund application with respect of any amount relating to CENVAT Credit, duty, tax, interest or any other amount paid under the existing law is to be disposed of in accordance with the provisions of existing law and if any such amount accrues the same shall be paid in cash. Such right to refund in cash has been conferred notwithstanding anything to the contrary contained under the provisions of existing law other than the provisions of sub-section (2) of section 11-B of the Central Excise Act, 1944. 42. It is not in dispute that the refunds under the existing law of Servic ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... h which the applications for refunds were pending or time limit for claiming refund was yet to expire or may crystalize on account of any judgement of courts or tribunals in relation to pending litigations. These are some of the situations which would be covered by the miscellaneous transitional provisions as contained in section 142(3) of CGST, Act which would continue to be governed by section 11B(2) of Central Excise Act, 1944. 45. The provision of section 142(3) does not entitle a person to seek refund who has no such right under the existing law or where the right under the existing law has extinguished or where right under the new CGST regime with respect to such claim has not been exercised in terms of the provision of CGST, Act and the rules framed and notifications issued. Meaning thereby, section 142(3) does not confer a new right which never existed under the old regime except to the manner of giving relief by refund in cash if the person is found entitled under the existing law in terms of the existing law. Section 142(3) does not create any new right on any person but it saves the existing right which existed on the appointed day and provides the modalities for re ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... reverse charge mechanism. Thus, the petitioner on the one hand illegally took credit of service tax on port services as credit in their ST-3 return and on the other hand filed application for refund of the same amount under section 142(3) of the CGST, Act which is certainly not permissible in law. The authorities have rightly considered these aspects of the matter also while rejecting the application for refund filed by the petitioner. 50. It is not in dispute that the petitioner has claimed the credit of service tax involved in the present case paid on port services as input service in ST-3 return filed on 22.09.2017, though they were not entitled to claim such a credit. It is further not in dispute that the petitioner did not include the impugned service tax paid on port services in its ER-1 return and accordingly was neither entitled to include nor included the same as transitional credit in TRAN-1 under CGST Act. As per the notification (Annexure-5) extending the date of filing TRAN-1 to 31.10.2017, the same was in relation to certain service tax issues which were paid after 30.06.2017 under reverse charge basis to cover instances of bills raised on 30.06.2017 sin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... pportunity to claim CENVAT Credit of service tax on port services in terms of the existing law read with section 140 of CGST, Act and had no existing right of refund on the date of coming into force of CGST, Act. The petitioner having not used the port services for export was not entitled to claim refund under the existing law. The petitioner was also not entitled to refund on account of the fact that the petitioner had already taken credit of the service tax paid on port services in ST-3 Return of service tax although admittedly the petitioner was not entitled to take such credit in ST-3 Return. On account of aforesaid three distinct reasons the petitioner was rightly held to be not entitled to refund under section 142(3) of CGST, Act by the impugned orders. 53. All the aforesaid provisions referred to and relied upon by the learned counsel of the petitioner do not entitle a person like the petitioner to any relief in the circumstances of acts and omissions of the service provider (port authority) or the service recipient (the petitioner) who have failed to comply the provision of law, both under the existing law and also under the CGST Act. The relied upon provisions of CGST ..... X X X X Extracts X X X X X X X X Extracts X X X X
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