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of Refund of excess availed/utilised Input Tax Credit - violation of Rule 36(4) of the CGST Rules, 2017 - Documentary proof of availing ITC - Belated filing of return - For the relevant period, though there is no extention of date of filing of GSTR Return, all that was done by means of subsequent Notifications was to waive/reduce late filing fee, interest, and penalty liabilities. - For the period to which the said proviso applies, the administrative instruction dated 11.11.2019 must survive in complete hibernation. Else, it may lose life to the higher statutory law. - HC
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