Returned refund claims filed within time were treated as resubmissions, not fresh claims, defeating limitation objections.

Refund claims filed within the limitation period and later returned only for lack of documents were treated as valid resubmissions, not fresh claims. A returned claim is not equivalent to a rejected claim for limitation purposes, especially where the return letter does not prescribe any time-limit for resubmission. On that basis, the later filings could not be held time-barred, and rejection solely on limitation was unsustainable. The matter was therefore remanded for decision on merits.

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Issues: Whether the refund claims, originally filed within limitation but later returned for want of documents and resubmitted, could be treated as time-barred and rejected.

Analysis: The original refund claims were filed within the limitation period. The refund sanctioning authority did not reject them on merits but only returned them because documents were missing. The return letter did not fix any time-limit for resubmission. In such circumstances, the later filing had to be treated as resubmission of the same refund claims and not as fresh claims. A returned claim cannot be equated with a rejected claim for the purpose of limitation, and the resubmitted claims therefore could not be held barred by time.

Conclusion: The refund claims were not time-barred and the rejection on limitation was unsustainable.

Final Conclusion: The impugned orders were set aside and the refund claims were remanded to be decided on merits.

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