Limitation for refund claims excluded period under later notification, making rejection solely on limitation unsustainable.

Refund applications rejected solely on limitation could not be sustained where a later CBDT notification excluded the period from 01.03.2020 to 28.02.2022 for computing limitation for refund claims. That exclusion removed the limitation basis relied on to deny the claims, so the rejection on limitation alone was unsustainable. The impugned orders were set aside.

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Issues: Whether rejection of refund applications solely on the ground of limitation was sustainable in view of the exclusion notified for the specified period.

Analysis: The refund claims were rejected only on limitation. A later notification issued by the Central Board of Indirect Taxes and Customs excluded the period from 01.03.2020 to 28.02.2022 for computing limitation for refund applications. On that basis, the limitation objection could not sustain the rejection of the claims.

Conclusion: The rejection of the refund applications on limitation alone was unsustainable and the impugned orders were set aside.

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