https://www.taxtmi.com/caselaws?id=202217 A beneficial refund-notification amendment substituting "six months" was treated as operating retrospectively where the claim was filed after the original two-month period but within six months. The analysis notes that, although exemption notifications are ordinarily construed strictly, substitution can indicate that the new words form part of the original provision, especially where a clarificatory circular had already extended the benefit for an earlier quarter. On that reading, the procedural time limit in the notification was applied broadly in favour of the refund claimant, and the claim could not be rejected as time-barred. en-us Fri, 17 Sep 2010 00:00:00 +0530 Tue, 08 Feb 2011 11:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=202217 A beneficial refund-notification amendment substituting "six months" was treated as operating retrospectively where the claim was filed after the original two-month period but within six months. The analysis notes that, although exemption notifications are ordinarily construed strictly, substitution can indicate that the new words form part of the original provision, especially where a clarificatory circular had already extended the benefit for an earlier quarter. On that reading, the procedural time limit in the notification was applied broadly in favour of the refund claimant, and the claim could not be rejected as time-barred. Case-Laws Service Tax Fri, 17 Sep 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=202217