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HC held that the conciliation agreement dated 09.10.2020 constitutes the relevant date for calculating limitation period under Section 54 of CGST Act. The settlement agreement, recognized under Arbitration & Conciliation Act, is equivalent to a civil court decree. Consequently, DMRC's refund applications filed on 17.01.2021 and 21.03.2021 were deemed timely. The court directed processing of refund with applicable interest within one month, setting aside the impugned orders and disposing of the petition accordingly.
HC held that the conciliation agreement dated 09.10.2020 constitutes the relevant date for calculating limitation period under Section 54 of CGST Act. The settlement agreement, recognized under Arbitration & Conciliation Act, is equivalent to a civil court decree. Consequently, DMRC's refund applications filed on 17.01.2021 and 21.03.2021 were deemed timely. The court directed processing of refund with applicable interest within one month, setting aside the impugned orders and disposing of the petition accordingly.
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