GST refund limitation issue over whether deficiency memo compliance amounts to a fresh refund application

GST refund under Section 54(1) is discussed in the context of whether compliance with a deficiency memo could be treated as a fresh refund application for limitation purposes. The document also notes the related appellate rejection on the same time-bar ground. Procedurally, the Gujarat High Court issued notice, returnable on 24 April 2025, and permitted direct service through email.

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Issues: Whether the refund application filed under Section 54(1) of the Central Goods and Services Tax Act, 2017 was rejected as time-barred by treating compliance with the deficiency memo as a fresh refund application, and whether the appellate rejection on the same ground required consideration.

Outcome: Notice issued, returnable on 24 April 2025, with direct service through email permitted.

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