Limitation exclusion for GST refund claims requires fresh consideration where later time relief brings applications within time.

The Delhi HC held that refund claims for accumulated input tax credit could not be sustained as time-barred once the later exclusion of the period from 01.03.2020 to 28.02.2022 was applied for limitation under Section 54 of the CGST Act. Since that exclusion could bring the applications within time, the earlier rejection orders based on limitation required reconsideration. The Court therefore set aside the rejection orders and remitted the refund claims to the competent authority for fresh decision in light of the later limitation exclusion.

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Issues: Whether the rejection of refund applications for accumulated input tax credit was liable to be interfered with in view of the subsequent exclusion of the period from 01.03.2020 to 28.02.2022 for computing limitation under Section 54 of the Central Goods and Services Tax Act, 2017, and whether the matter required fresh consideration by the refund authority.

Analysis: The refund applications had been rejected as belated, and the subsequent exclusion of the relevant period for limitation purposes rendered the applications within time. In these circumstances, the rejection could not stand without reconsideration of the refund claims in the light of the later circular giving effect to the exclusion of time.

Conclusion: The rejection orders were set aside and the refund applications were remitted to the authority for fresh decision in accordance with the later limitation exclusion.

Final Conclusion: The petition succeeded to the extent of setting aside the impugned refund rejection orders and directing reconsideration of the refund claims.

Ratio Decidendi: Where a later legal development excludes a period for limitation computation and thereby brings a refund claim within time, the rejection of the claim on the earlier limitation basis warrants fresh adjudication by the competent authority.

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