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The adjudicating authority has rightly and properly rejected all the refund applications on the ground of time barred. There is no force in the contention of the appellant that the date of initial filing of application should have been taken for considering the relevant period of two years as it is against the provisions of sub-rule (3) of CGST Rule 90 of the CGST Rules, 2017.

Section 54 of the CGST Act, 2017 — Refund — The appellant filed refund applications. The adjudicating authority rejected the refund claim as time barred in as much as the claimant may make the application for refund of any amount before the expiry of 2 years from the relevant date as per Section 54(1) of Act, 2017. Being aggrieved the appellant filed appeal. The authority observed that the adjudicating authority has rightly and properly rejected all the refund applications on the ground of time barred. There is no force in the contention of the appellant that the date of initial filing of application should have been taken for considering the relevant period of two years as it is against the provisions of sub-rule (3) of Rule 90 of the CGST Rules, 2017. Held that:- The Hon’ble authority rejected the appeal.
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