Interest should commence to run from the date on which the petitioner parted with the money in the first instance and was restrained from using such an amount representing the IGST on the component of “ocean freight”.

A refund claimed under RCM cannot be diverted to the Consumer Welfare Fund solely because service tax has been reflected on the expense side in the books of accounts.

This safeguard will avert both inadvertent lapses and deliberate attempts by assessees to buy time or manipulate timelines.