CENVAT refund time limit and clarificatory notification issues admitted for consideration in export service refund dispute.

A refund claim for CENVAT credit used as input services for export of service under Notification No. 5/2006 raised two linked issues: whether any time limit applied to the refund application, and whether Notification No. 14/2016 was merely clarificatory. The Gujarat High Court admitted the tax appeal for consideration of the stated substantial question of law, leaving the issues open for determination on merits.

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Issues: Whether any time limit applied to an application for refund of CENVAT credit in respect of services used as input services for export of service under Notification No. 5/2006 dated 14.03.2006, and whether Notification No. 14/2016 dated 01.03.2016 was merely clarificatory.

Outcome: The tax appeal was admitted for consideration of the stated substantial question of law.

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