https://www.taxtmi.com/caselaws?id=771812 Under section 54 of the CGST Act, the relevant date for refund limitation was held to be the date on which the conciliation settlement was finalised, because that settlement finally fixed the contractual value and crystallised the excess tax paid. Explanation 2(d) applied since the tax became refundable by reason of a binding settlement treated as having final effect akin to an arbitral award. Explanation 2(h), being residual, did not govern where a specific explanation applied. Refund applications filed after the settlement were therefore within limitation. en-us Wed, 21 May 2025 00:00:00 +0530 Fri, 06 Jun 2025 14:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771812 Under section 54 of the CGST Act, the relevant date for refund limitation was held to be the date on which the conciliation settlement was finalised, because that settlement finally fixed the contractual value and crystallised the excess tax paid. Explanation 2(d) applied since the tax became refundable by reason of a binding settlement treated as having final effect akin to an arbitral award. Explanation 2(h), being residual, did not govern where a specific explanation applied. Refund applications filed after the settlement were therefore within limitation. Case-Laws GST Wed, 21 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771812