Withholding refund by order by Commissioner, if matter is in appeal :
If an order giving rise to a refund is the subject matter of an appeal or further proceeding or where any other proceeding under this Act is pending and the Commissioner is of the opinion that grant of such refund is likely to adversely affect the revenue in the said appeal or other proceedings on account of malfeasance or fraud committed, he may, after giving the taxpayer an opportunity of being heard, withhold the refund till such time as he may determine – section 54(11) of CGST Act.
Where a refund is withheld under section 54(11), the taxable person shall be entitled to interest at rate not exceeding 6% as may be notified on recommendation of GST Council, if as a result of the appeal or further proceeding he becomes entitled to refund – section 54(12) of CGST Act.