Electronic filing controls refund limitation where later physical copies are filed after a timely online application.

For refund claims under Notification No. 5/2006-CE (N.T.), where electronic filing through ACES was permitted, the date of electronic filing is the relevant date for limitation. The later submission of physical copies did not override the timely electronic application or render the claim time-barred, especially where the trade notice and Board circular allowed and encouraged electronic filing. The limitation objection was therefore unsustainable, and the refund claim could not be rejected on the ground of delayed physical documentation. The original authority was directed to process the refund on the basis of the electronic filing date.

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Issues: Whether the refund claim under Notification No. 5/2006-CE (N.T.) dated 14.03.2006 was barred by limitation because the physical documents were filed after the electronic filing of the refund application.

Analysis: The refund application and supporting documents were filed electronically within the prescribed time through ACES. The later submission of physical copies could not override the initial electronic filing, particularly when the relevant trade notice and Board circular permitted and encouraged electronic filing. The claim was therefore to be reckoned from the date of electronic filing, and the later physical submission did not make the claim time-barred.

Conclusion: The limitation objection was unsustainable and the refund claim could not be rejected as time-barred.

Final Conclusion: The impugned order was set aside and the original authority was directed to process the refund claim on the basis of the electronic filing date as the relevant date.

Ratio Decidendi: For refund claims permitted to be filed electronically, the date of electronic filing is the relevant date for limitation, and subsequent physical submission of documents does not render the claim time-barred.

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