GST refund claim after deficiency memo: limitation u/s54(3) runs from first filing; time-bar rejection quashed, remanded.
Case-Laws
GST
Refund was rejected as time-barred under s.54(3) CGST Act by treating a later revised application (filed after a deficiency memo) as the relevant date for limitation. The Court held that limitation must be computed from the date of the initial refund application, and a subsequent revised filing pursuant to a deficiency memo cannot shift the limitation s
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