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    <title>2025 (12) TMI 1058 - GUJARAT HIGH COURT</title>
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    <description>A refund claim filed for an earlier tax period could not be denied merely because the application was submitted after the notification date, where it was otherwise within the statutory limitation under section 54. Paragraph 2(2) of Circular No. 181/13/2022-GST was held invalid for creating an artificial and discriminatory cutoff, and was struck down as ultra vires the Gujarat GST Act and violative of Article 14. As the refund rejections and appellate orders rested on that circular, they could not survive and the refund applications were directed to be processed in accordance with law.</description>
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      <description>A refund claim filed for an earlier tax period could not be denied merely because the application was submitted after the notification date, where it was otherwise within the statutory limitation under section 54. Paragraph 2(2) of Circular No. 181/13/2022-GST was held invalid for creating an artificial and discriminatory cutoff, and was struck down as ultra vires the Gujarat GST Act and violative of Article 14. As the refund rejections and appellate orders rested on that circular, they could not survive and the refund applications were directed to be processed in accordance with law.</description>
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