Case of Union of India vs Torrent Power Limited, SC Judgement Dated 10th February 2026. The apex court held that Section 54 of the CGST Act constitutes a complete statutory code governing refund. Any refundable amount shall be credited to the Consumer Welfare Fund unless it falls within the exceptions enumerated in the said section. Section 54(8)(e) specifically provides that refund may be paid to the applicant only if the applicant has not passed on the incidence of tax and interest to any other person. . The court further held that, court are not allowed to invent the new modality for refund, which is not contemplated by the provision of Law nor rules. It ruled that since the tax incidence was passed to consumers, the refund must go to the Consumer Welfare Fund.