Refund limitation for accumulated input tax credit: manual filing date treated as relevant date for fresh online claims.

For refund claims of accumulated input tax credit under the CGST regime, where online filing had failed due to technical issues, the date of manual filing was directed to be treated as the relevant date for limitation under Section 54. Fresh online refund applications were to be processed on that basis, enabling consideration of the claims in accordance with law.

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Issues: Whether the date of manual filing of the refund application could be treated as the relevant date for computing limitation and processing fresh online refund applications for refund of accumulated input tax credit under the CGST regime.

Analysis: The petitions concerned refund of accumulated input tax credit arising from an inverted tax structure. The Court noted the petitioner's grievance that online filing had earlier failed because of technical issues, while the revenue stated that fresh online applications could now be filed and considered subject to limitation. In this context, the Court directed that the date of filing of the refund application to be preferred online be treated as the date of the manual refund application for the purpose of limitation under Section 54, so that the refund claims could be processed in accordance with law.

Conclusion: The date of manual filing was directed to be treated as the relevant date for limitation, and the petitioner was entitled to have the fresh refund applications processed on that basis.

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