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    <description>Unadjusted input tax rebate remaining after two years from the close of the relevant financial year was treated as refundable under the proviso to Section 14(3) of the Madhya Pradesh Value Added Tax Act, 2002. The later action under Section 47(2) was distinguished from a review of the refund sanction because it was taken under statutory power rather than by reopening a judicial determination. The final order was also found unsustainable because it proceeded on grounds not contained in the show cause notice, which offended the requirement of fair hearing and natural justice.</description>
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