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HC found the refund claim for unutilized input tax credit time-barred u/s 54. The court interpreted Section 54(1) and 54(3) to establish that while refund claims can be initiated from the end of the relevant tax period, there exists a two-year limitation period from the relevant date. The petitioner's application filed on 21.03.2024 exceeded the statutory deadline of 09.03.2024. The court emphasized that Section 54(3) determines the starting point for refund claims, while Section 54(1) sets the outer time limit of two years. Given the clear statutory framework and the petitioner's failure to file within prescribed time limits, the petition was dismissed.
HC found the refund claim for unutilized input tax credit time-barred u/s 54. The court interpreted Section 54(1) and 54(3) to establish that while refund claims can be initiated from the end of the relevant tax period, there exists a two-year limitation period from the relevant date. The petitioner's application filed on 21.03.2024 exceeded the statutory deadline of 09.03.2024. The court emphasized that Section 54(3) determines the starting point for refund claims, while Section 54(1) sets the outer time limit of two years. Given the clear statutory framework and the petitioner's failure to file within prescribed time limits, the petition was dismissed.
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