No limitation period for additional credit claim meant later six-month amendment could not bar the application retrospectively.

An application for additional credit could not be rejected as time-barred because, on the date of filing, the statute prescribed no limitation period for such a claim. A later amendment introducing a six-month limit operated prospectively and was not shown to have retrospective effect. A reasonable period may be read into a limitation scheme only where the statute already creates time discipline; it cannot be used to import a restriction where none existed. On that basis, denial of the additional credit on delay was unsustainable and the claim was not barred by limitation.

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Issues: Whether the assessee's claim for additional credit could be rejected as time-barred when no limitation period was prescribed on the date of the application.

Analysis: The relevant application was made when the statute did not prescribe any time limit for seeking additional credit. The later amendment introducing a six-month period operated only prospectively and was not shown to have retrospective effect. The principle that a reasonable period may be read into a limitation framework applies where the statute itself creates a time discipline; it cannot be used to import a limitation where none existed. On that basis, the rejection of the claim on delay was unsustainable.

Conclusion: The assessee's claim was not barred by limitation and the denial of additional credit was ?

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