𝗦𝗲𝗿𝘃𝗶𝗰𝗲 𝗧𝗮𝘅 – 𝗖𝗘𝗦𝗧𝗔𝗧 𝗡𝗲𝘄 𝗗𝗲𝗹𝗵𝗶 𝗥𝘂𝗹𝗶𝗻𝗴 𝗼𝗻 𝗥𝗲𝗳𝘂𝗻𝗱 𝗮𝗻𝗱 𝗨𝗻𝗷𝘂𝘀𝘁 𝗘𝗻𝗿𝗶𝗰𝗵𝗺𝗲𝗻𝘁 📢 𝗧𝗵𝗲 𝗧𝗿𝗶𝗯𝘂𝗻𝗮𝗹 𝗵𝗲𝗹𝗱: "Deposits made during adjudication or investigation are not payments of service tax or excise duty. Principles of unjust enrichment do not apply, and refunds are admissible with interest."

🔍 𝗙𝗮𝗰𝘁𝘀: 𝗖𝗼𝗺𝗽𝗮𝗻𝘆: M/s Chambal Fertilizers and Chemicals Limited 𝗜𝘀𝘀𝘂𝗲: Refund claim of service tax deposit rejected due to unjust enrichment. 𝗔𝗰𝘁𝗶𝘃𝗶𝘁𝘆: Agreements for importing intellectual property rights services in 2006–2007; service tax was paid under protest.

⚖️ 𝗝𝘂𝗱𝗴𝗲𝗺𝗲𝗻𝘁: The Tribunal ruled that deposits during adjudication are not service tax payments. Refunds are admissible regardless of accounting methods or pricing set by the government. Appeal allowed, refund granted with applicable interest.

📜 𝗖𝗮𝘀𝗲 𝗜𝗻𝗳𝗼𝗿𝗺𝗮𝘁𝗶𝗼𝗻: 𝗧𝗶𝘁𝗹𝗲: M/s Chambal Fertilizers and Chemicals Limited vs. Commissioner, CGST 𝗢𝗿𝗱𝗲𝗿 𝗗𝗮𝘁𝗲: 30 January 2023 This ruling underscores that unjust enrichment principles do not impede refunds for deposits during investigations.