Appellate-order refund limitation may use delayed portal upload date, preserving timely claims and triggering interest for non-payment.
Case-Laws
GST
Refund limitation following an appellate order setting aside a tax and penalty demand may, in exceptional circumstances, run from the belated portal upload of Form GST APL-04 rather than physical communication of the order. Although physical communication ordinarily constitutes the relevant date and the refund form does not require awaiting portal upload, treating the later upload date as relevant preserved express appellate refund relief where the application was filed immediately thereafter. The refund rejection was quashed and processing directed. Interest was payable at 6% from the court-fixed date until payment, rising to 9% if directions remained unimplemented after the stipulated period.
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