As per case facts, the petitioner imported raw materials and paid IGST on “ocean freight” under protest as per certain notifications. These notifications were challenged and eventually declared unconstitutional by ... the Supreme Court. Consequently, the petitioner received a refund of the IGST paid but was denied interest by the tax authorities, who stated the refund was processed within the statutory period. The petitioner appealed to the High Court, contending that the tax was collected without legal authority and interest should be paid from the date of deposit. The question arose whether the petitioner was entitled to interest on the unconstitutionally levied IGST from the date of its deposit, irrespective of the statutory refund interest provisions. Finally, the High Court held that the tax collection was illegal from inception, and therefore, the petitioner is entitled to interest at 6% per annum from the date of deposit until actual refund, with 9% for further delay, emphasizing that statutory delayed refund interest provisions do not apply to unauthorized collections.