Galaxy Match Company vs Commissioner Of Gst&Cce(Madurai) on 13 April, 2026
), and G.S. Radiators Ltd. vs CCE, 2005 (179) E.L.T.
222 (Tri.-Del.), wherein it has been held that payments
made during investigation or pendency of dispute are to be
treated as deposits under protest. The ratio decidendi of
these decisions is that prior to adjudication, the liability is
not crystallized and therefore such payments do not assume
the character of duty.