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Rejection of refund of unutilized Input Tax Credit (ITC) due to delay of 2 days beyond the 60-day statutory limit u/s 54(7) of the Act. Court held that the term 'shall' in the section is directory, not mandatory, considering the availability of interest on delayed refunds u/s 56. Rigid adherence to the time limit would not serve the legislative intent. The impugned orders were deemed well-reasoned, with no procedural flaws or legal violations. Petitioner failed to show any merit for interference. High Court dismissed the application, finding no grounds for intervention.