Offline refund claims remain valid where manual filing is permitted, and delayed GST refunds attract statutory interest.

A refund claim could not be rejected merely because it was filed offline where the rules permitted manual filing in place of electronic submission, and a timely physical application remained valid. The refund arose from the appellate relief, and procedural insistence on portal filing could not override the substantive right to refund. As the refund was not granted within the prescribed sixty-day period, statutory interest became payable on the delayed amount under the Act.

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Issues: (i) Whether a refund claim could be maintained on a physical or offline application when the refund portal allegedly did not permit electronic filing. (ii) Whether the revenue was liable to grant refund with statutory interest for delay beyond the prescribed period.

Issue (i): Whether a refund claim could be maintained on a physical or offline application when the refund portal allegedly did not permit electronic filing.

Analysis: The refund became due upon the appellate order granting relief and directing refund of the recovered amount. Section 54 of the Uttar Pradesh Goods and Services Tax Act, 2017 required a claim to be filed in the prescribed manner, and Rule 97-A of the Uttar Pradesh Goods and Services Tax Rules, 2017 expressly permitted manual filing where electronic filing was contemplated. The physical application filed within the limitation period was not disputed, and procedural insistence on online filing could not defeat the substantive refund claim.

Conclusion: The offline refund application was valid and maintainable.

Issue (ii): Whether the revenue was liable to grant refund with statutory interest for delay beyond the prescribed period.

Analysis: The appellate order had attained finality and the amount could not lawfully be retained by the State. Under Section 54(7) of the Uttar Pradesh Goods and Services Tax Act, 2017, the refund application had to be disposed of within sixty days of receipt, and under Section 56 of the same Act, delay beyond that period attracted interest at the statutory rate. As the refund was not released within time, the statutory consequence of interest followed.

Conclusion: The revenue was liable to refund the amount together with statutory interest.

Final Conclusion: The petition succeeded, the refund claim was held to be legally entertainable on a manual application, and the authorities were directed to release the refund with interest in accordance with the statute.

Ratio Decidendi: Where the statute or rules permit manual filing in place of electronic filing, a validly filed offline refund claim cannot be rejected on the ground of portal-based non-compliance, and delay in granting a due refund attracts statutory interest after expiry of the prescribed period.

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