The CESTAT held that the substitution of Entry No. 25(a) in...

The CESTAT held that the substitution of Entry No. 25(a) in Notification No. 25/2012-ST by Notification No. 6/2014-ST is prospective, not retrospective, and thus the unamended notification governs the refund claim period. The appellant, a governmental authority, is entitled to exemption under the unamended clause 25(a) for services related to water supply, subject to proving entitlement. However, the refund claim is restricted by the limitation period under Section 11B of the Central Excise Act, as applicable to the Finance Act, allowing recovery only for tax paid within the prescribed timeframe. The appeal was allowed in part, and the matter remanded for quantification of the refundable amount within limitation, conditioned on the appellant submitting an independent chartered accountant's certificate confirming no unjust enrichment. The impugned order was set aside accordingly.