Limitation for export service refund claims cannot be revived by a later notification extending the filing window.

Refund claims for export-related services are subject to the time limit in the relevant exemption notification, and a later extension cannot revive a claim that had already become time-barred. Where the claim period had expired before Notification No. 32/2008-ST extended the filing window, the extended six-month period did not apply to the earlier lapse. The text applies strict construction of exemption notifications and treats the refund claim as barred by limitation on that basis.

---

---

Issues: Whether the refund claim arising from export-related services was barred by limitation under the applicable notification.

Analysis: The refund claim related to the quarter 01.10.2007 to 31.12.2007, while the prescribed time limit under the relevant notification stood extended only later by Notification No. 32/2008-ST dated 18.11.2008. By that date, the period available for filing the claim had already expired. The extended six-month period could not revive a claim that had already become time-barred. In view of the strict construction applicable to exemption notifications, the extension did not enure to the appellant's benefit.

Conclusion: The refund claim was time-barred and the appeal failed.

---