"Sreeranjan N.G., GST Practitioner (GSTP) is a seasoned indirect tax professional based in Karnataka with extensive experience in GST litigation, advisory, and strategic tax planning across diverse industries. He has successfully handled numerous GST assessments, investigations, and appellate proceedings, assisting clients in developing strong legal strategies and representing them before tax authorities. Known for his practical and litigation-oriented approach, he has also played a key role in drafting writ petitions, assisting senior counsel in high-stakes matters, and resolving complex tax disputes. In addition to professional practice, he actively contributes to the tax community through technical articles, professional training sessions, and knowledge sharing programs for industry and tax professionals. He is also a member of the Karnataka State Tax Practitioners Association, and is recognized for his insightful analysis of evolving GST jurisprudence and policy developments."
Refunds under customs law are allowed only when the claimant proves the duty burden was not passed to another. Courts have held that failure to establish this results in denial of refund and credit to the Consumer Welfare Fund.
Section 54 applies only to refunds of legally recognized tax, not all payments made to the Government. The ruling highlights the need to first determine whether the amount qualifies as “tax.”
The court held that concessional GST applies only when prescribed supply routes are followed. Even genuine exports fail if conditions are not strictly met.
Courts have addressed whether time spent pursuing rectification affects the limitation for GST appeals. The rulings aim to ensure taxpayers do not lose their right to appeal due to rectification proceedings.
The Budget 2026 amendment to the intermediary provision raises questions about the validity of ongoing GST disputes. Without a saving clause, taxpayers may argue that pending proceedings lack statutory support.
