Limitation for Revenue refund appeals begins when the order is issued, barring delayed departmental challenges beyond condonable time.
Case-Laws
GST
Limitation for Revenue appeals against refund sanction orders under Section 107(2) of the CGST Act runs from communication of the adjudicating order, construed for intra-departmental purposes as the date of its issuance. Online transmission of refund orders to the review module and their availability on the common portal constitutes service; internal administrative transmission cannot create an indefinite extension. The six-month appeal period may be extended by only one further month under Section 107(4). Post-audit dates and the separate recovery mechanism for erroneous refunds do not enlarge appellate limitation. Appeals filed beyond this period are time-barred and cannot be condoned.
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