Held - I find that the Hon'ble High Court of Bombay in the case of Parijat Construction Vs. Commissioner of Central Excise, Nashik [2018 (359) ELT 113 (Bom.)], had held that the limitation prescribed under 11B of the Central Excise Act, 1944, is not applicable to refund claim for service tax paid under mistake of law. 

Therefore, even in the present case, the amount paid by the Appellant was not tax and was never leviable under the .....

Held - The peculiar facts of the present case are that the appellant has paid the tax twice and that the Revenue has not disputed the same. In view of the above, it has to be presumed that there has, in fact, been double payment of tax: firstly, under the Service Tax regime and secondly, again under the G.S.T. regime.  

Higher courts have held that no tax shall be collected without the authority of law and, as a necessary corollary,.....