Mohit Minerals - IGST Refund follow-on
Facts
After the SC struck down IGST on ocean freight, importers sought refund of GST already paid.
Issue
Refund mechanism for an unconstitutional levy.
Held
GST paid under invalid notification is refundable; limitation under Section 54 of CGST Act does not bar refund of constitutionally invalid tax.
Ratio
Unjust enrichment doctrine applies but does not extinguish the substantive right to refund.
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