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In the writ petitions filed by Mr.Narayanan apart from rejecting the request on the ground of limitation, the authority also mentions the non-availability of certain statutory / other documents in support of the claim for refund. In the writ petitions filed by Mr.Shanmugam, the rejection is solely on the basis of limitation.

Section 54 of the CGST Act, 2017— Refund —-- The petitioner challenged the orders rejecting refund and appellate orders confirming such rejection, on the ground of limitation. The CBIC vide Notification No.13/2022 - Central Tax dated 05.07.2022, stated that the time between 01.03.2020 - 28.02.2022 shall stand excluded.

Held that:- The Hon’ble High Court set aside the Orders and restored the refund applications to the file of the assessing authority and directed that Refund shall be paid over within six weeks.

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