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    <title>2023 (7) TMI 661 - JAMMU AND KASHMIR AND LADAKH HIGH COURT</title>
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    <description>The court dismissed the appeal, holding that the extended period of limitation under Section 11A was not applicable as there was no evidence of willful suppression or fraud by the respondent in claiming an erroneous refund. It was ruled that the refund orders, which had not been challenged and had attained finality, could not be considered &#039;erroneous refunds&#039; subject to recovery under Section 11A. The court emphasized that unless these orders were overturned through appeal or revision, they could not be invalidated through collateral proceedings.</description>
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      <description>The court dismissed the appeal, holding that the extended period of limitation under Section 11A was not applicable as there was no evidence of willful suppression or fraud by the respondent in claiming an erroneous refund. It was ruled that the refund orders, which had not been challenged and had attained finality, could not be considered &#039;erroneous refunds&#039; subject to recovery under Section 11A. The court emphasized that unless these orders were overturned through appeal or revision, they could not be invalidated through collateral proceedings.</description>
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