GST refund limitation runs prospectively, and manual filing is permissible when the portal will not accept refund applications.

An amendment to the GST refund limitation provision was treated as prospective, so the change in the definition of "relevant date" did not bar the December 2017 refund claim, which was also found to be within time after exclusion of the Supreme Court-directed limitation period. For the January to March 2018 claims, Rule 97-A permitted manual filing where the portal would not accept refund applications, and the electronic filing defect justified processing the claims manually. The refund applications were therefore required to be entertained and processed under the applicable refund procedure.

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Issues: (i) Whether the refund application for December 2017 was barred by limitation in view of the amended definition of "relevant date" under Section 54(1) of the Central Goods and Services Tax Act, 2017. (ii) Whether the refund applications for January to March 2018 could be filed and processed manually when the portal did not accept them.

Issue (i): Whether the refund application for December 2017 was barred by limitation in view of the amended definition of "relevant date" under Section 54(1) of the Central Goods and Services Tax Act, 2017.

Analysis: The amended definition of "relevant date" was treated as prospective in operation. The application was also considered within time after excluding the period directed by the Supreme Court for limitation purposes. On that basis, the refund claim for December 2017 could not be rejected as time-barred.

Conclusion: The objection of limitation was rejected and the refund application for December 2017 was held to be within time.

Issue (ii): Whether the refund applications for January to March 2018 could be filed and processed manually when the portal did not accept them.

Analysis: Rule 97-A of the Central Goods and Services Tax Rules, 2017 was applied to hold that manual filing was permissible where the portal did not accept the refund applications. The record showed that the electronic filing mechanism was not accepting the applications for the later months.

Conclusion: The petitioner was held entitled to file the refund applications manually and have them processed.

Final Conclusion: The refund applications were required to be entertained and processed in accordance with the applicable rules.

Ratio Decidendi: An amendment altering the "relevant date" for refund limitation operates prospectively unless expressly made retrospective, and where the statutory portal does not accept a refund claim, manual filing remains permissible under the refund procedure.

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