Amendment to the definition of "relevant date" for refund of unutilised input tax credit under the inverted duty structure cannot be applied retrospectively to curtail refund claims for pre-amendment periods. A vested right to seek refund accrued before the amendment cannot be taken away unless retrospective operation is expressly provided. The refund claim for July 2017 to December 2018 was not time-barred under the extended limitation period, and the claim for January to March 2019 was also not barred under the refund provision. (AI Summary)
TaxTMI