Finality of assessment and limitation barred belated claim for tax exemption adjustment or refund.

A belated request to adjust or refund the unallowed balance of tax exemption was rejected because the relevant KST assessment orders had already attained finality and no timely challenge had been made to the entitlement certificate or assessments. The court noted that the revised entitlement certificate had already been acted upon, the earlier VAT-related directions had been complied with, and there was no subsisting to reopen concluded assessments through rectification. The claim was also held to be barred by limitation, so the impugned endorsement was sustained and the writ petition failed.

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Issues: Whether the petitioner was entitled to have the unallowed balance of tax exemption adjusted against its tax liability or refunded, despite the assessment orders having attained finality and the claim being made belatedly.

Analysis: The assessment orders relating to the KST period had attained finality, and the petitioner had not raised any challenge to the entitlement certificate or the assessment orders within time. The request for rectification was made only in 2018, long after the relevant assessments were concluded. The revised entitlement certificate and the earlier directions regarding the VAT period had also been complied with, and there was no subsisting basis to reopen the settled KST assessments at that stage. The claim was also held to be barred by limitation.

Conclusion: The petitioner was not entitled to adjustment or refund of the unallowed tax exemption amount, and the impugned endorsement was sustained.

Final Conclusion: A belated claim to reopen final assessment proceedings for the purpose of adjusting tax exemption could not be entertained, and the writ petition failed.

Ratio Decidendi: Once assessment orders have attained finality and the claim is time-barred, a subsequent request for adjustment or refund of tax exemption cannot be entertained.

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