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of <h1>Refund Applications for May 2019-September 2019 Reinstated After Limitation Period Exclusion Under Statutory Notification</h1> <h3>Zenon Analytics Pvt. Ltd. Versus Union Of India & Anr.</h3> Zenon Analytics Pvt. Ltd. Versus Union Of India & Anr. - TMI Issues involved: The issue involves the rejection of refund applications for the periods May 2019 to July 2019 and August 2019 to September 2019 solely on the ground of limitation.Summary:Issue 1: Rejection of refund applications based on limitationThe petitioner challenged two orders dated 11.01.2022, which rejected the refund applications for the specified periods due to limitation. The petitioner relied on a Notification dated 05.07.2022, excluding the period between 01.03.2020 to 28.02.2022 for computation of the limitation period. The respondent argued that their counter affidavit was filed before the publication of the said Notification. The Court found that the petitioner's case fell within the scope of the Notification, which rendered the rejection on the basis of limitation unsustainable. Consequently, the impugned orders were set aside, and the refund applications were restored for the Assessing Authority to decide within four weeks.This judgment highlights the importance of statutory notifications in determining the computation of limitation periods for refund applications, ensuring fair treatment and adherence to legal provisions in such matters.
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