Refund limitation cannot defeat a timely claim when later amendment only corrects the quantified amount.

A refund claim filed within the statutory limitation period after finalisation of provisional assessment was not rendered time-barred merely because the assessee later amended the amount to correct the payable quantum. The amendment was treated as a verification-based correction to quantify the original claim, not as a fresh refund application attracting limitation. Once the original claim was timely filed and pending consideration, it could not be rejected as barred by time on the basis of the later amendment. The assessee's claim therefore succeeded.

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Issues: Whether the refund claim filed within limitation could be rejected as time-barred on the ground that the assessee later amended the claim to correct the refund amount after finalisation of provisional assessment.

Analysis: The refund claim was originally filed within the statutory period after finalisation of provisional assessment. The later amendment only corrected the quantum payable on verification and did not amount to a fresh claim so as to attract limitation. Once the original claim was within time, the amendment to quantify the correct amount could not be treated as a time-barred independent claim. Rejection of the claim as barred by limitation therefore failed to give effect to the earlier finding that the original claim had been duly filed and was pending consideration.

Conclusion: The refund claim could not be rejected as time-barred merely because the amount was later amended, and the assessee succeeded.

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