GST refund limitation bars mandamus where the refund claim and later request were both filed beyond the statutory time limit.

A writ of mandamus will not be issued to compel reconsideration of a GST refund claim filed beyond the statutory two-year limitation period from the relevant date. Where the refund application is time-barred and a later request seeks the same relief on the same factual basis, no ground exists for judicial interference. The refund claim was therefore treated as barred by limitation, and mandamus was refused.

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Issues: Whether a writ of mandamus could be issued to direct consideration of a refund request filed beyond the limitation period prescribed for refund under the GST framework.

Analysis: The refund application was found to have been made beyond the statutory time limit of two years from the relevant date under the refund provision. The petitioner's subsequent request was also presented much later and sought the same relief on the same factual basis. In these circumstances, no ground was made out for judicial interference to compel reconsideration of a time-barred refund claim.

Conclusion: The refund claim was held to be barred by limitation, and the request for mandamus was rejected.

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