Limitation for service tax refund on exported services bars a claim filed late and cannot be saved by later completion dates.

Refund of service tax paid on exported services was assessed against the notified limitation period, and a claim filed after the relevant payment dates was treated as time-barred. On the appellant's own dates of receipt, the one-year limit was exceeded; on later completion and balance-payment dates, the claim would instead be premature. The amended notification introducing the time limit was treated as applicable, and the refund rejection was regarded as consistent with the governing refund conditions.

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Issues: Whether the refund claim for service tax paid in respect of exported services was barred by limitation and therefore liable to rejection.

Analysis: The refund claim was filed long after the relevant payments were received, and even on the appellant's own case, the claim could not escape the one-year limit. If the part-payments received in 2014 and 2015 were taken as the relevant dates, the claim was beyond time; if the later completion and balance-payment dates were taken, the claim was premature. The amended notification introducing the time-limit was treated as applicable to the claim, and the authorities' rejection was found to be consistent with the governing refund conditions.

Conclusion: The refund claim was held to be time-barred and properly rejected.

Ratio Decidendi: A refund claim governed by the notified limitation period cannot be entertained when it is filed beyond time on the relevant payment dates, and it cannot alternatively succeed on a later completion date if, on that footing, it is premature.

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