https://www.taxtmi.com/caselaws?id=365350 The court upheld the rejection of the refund claim as it was filed beyond the six-month limitation period under Section 103(3) of the Finance Act, 1994. It determined that the provision is a policy decision not subject to judicial review, emphasizing that the exemption and refund are conditional privileges, not rights. The court also clarified that the limitation period starts from the date of assent to the Finance Bill, 2016, and procedural delays by the Ministry do not affect this timeline. The court dismissed the petition, concluding that Section 103(3) is not discriminatory or unconstitutional. en-us Wed, 27 Jun 2018 00:00:00 +0530 Sat, 05 Jun 2021 11:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=365350 The court upheld the rejection of the refund claim as it was filed beyond the six-month limitation period under Section 103(3) of the Finance Act, 1994. It determined that the provision is a policy decision not subject to judicial review, emphasizing that the exemption and refund are conditional privileges, not rights. The court also clarified that the limitation period starts from the date of assent to the Finance Bill, 2016, and procedural delays by the Ministry do not affect this timeline. The court dismissed the petition, concluding that Section 103(3) is not discriminatory or unconstitutional. Case-Laws Service Tax Wed, 27 Jun 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=365350