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    <title>2026 (2) TMI 1101 - ORISSA HIGH COURT</title>
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    <description>Rejection of a refund claim solely on the ground that it was filed beyond the statutory period under Section 54 of the CGST Act is unsustainable where identical tax was paid twice and supporting payment evidence was placed before the authority. The principles governing recovery of amounts retained without legal authority and claims arising from mistake of law-including Limitation Act doctrines and discovery of mistake-apply and can displace the special-law time bar. An administrative rejection must stand on its stated grounds; the payment evidence obliges reconsideration and a fresh refund filing and decision in accordance with law.</description>
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      <description>Rejection of a refund claim solely on the ground that it was filed beyond the statutory period under Section 54 of the CGST Act is unsustainable where identical tax was paid twice and supporting payment evidence was placed before the authority. The principles governing recovery of amounts retained without legal authority and claims arising from mistake of law-including Limitation Act doctrines and discovery of mistake-apply and can displace the special-law time bar. An administrative rejection must stand on its stated grounds; the payment evidence obliges reconsideration and a fresh refund filing and decision in accordance with law.</description>
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