https://www.taxtmi.com/caselaws?id=372349 The court upheld the constitutionality of sub-section (3) of Section 103 of the Finance Act, 1994, interpreting that the time taken by the Ministry for processing the necessary certificate should be excluded from the six-month limitation period for refund applications. The court affirmed the mandatory nature of the six-month limitation period under Section 103, emphasizing its self-contained mechanism for tax exemptions and refunds. It clarified that the requirement of obtaining a certificate and the limitation period are distinct conditions to be met. The court rejected the argument to apply other statutory limitation periods, affirming the exclusivity of the six-month period under Section 103. Consequently, the court upheld the rejection of refund claims due to late filing. en-us Fri, 14 Dec 2018 00:00:00 +0530 Tue, 09 Apr 2019 11:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=372349 The court upheld the constitutionality of sub-section (3) of Section 103 of the Finance Act, 1994, interpreting that the time taken by the Ministry for processing the necessary certificate should be excluded from the six-month limitation period for refund applications. The court affirmed the mandatory nature of the six-month limitation period under Section 103, emphasizing its self-contained mechanism for tax exemptions and refunds. It clarified that the requirement of obtaining a certificate and the limitation period are distinct conditions to be met. The court rejected the argument to apply other statutory limitation periods, affirming the exclusivity of the six-month period under Section 103. Consequently, the court upheld the rejection of refund claims due to late filing. Case-Laws Service Tax Fri, 14 Dec 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=372349