IGST refund on exports cannot be confined to a request to amend...

IGST refund on exports cannot be confined to a request to amend shipping bills under Section 149 when an independent refund prayer under Rule 96 is on record. The refund rejection was set aside because the authority considered only the alleged lack of contemporaneous evidence for amendment and failed to examine the refund claim on its own merits. As export of goods and payment of IGST were undisputed, and none of the Rule 96(4) withholding contingencies applied, the refund had to be processed under the statutory refund mechanism; the amendment issue was left open.