https://www.taxtmi.com/highlights?id=97955 Filing a refund application within two years under Section 54 is a mandatory statutory limitation that bars the proper officer from entertaining belated claims; the absence of any provision to condone delay means the officer lacks jurisdiction except where the statute permits relief. Where the Act provides no remedy, a writ under Article 226 may be entertained to seek condonation of delay, subject to consideration of laches and bona fides. Any judicial condonation must be conditional: the taxpayer may obtain relief only if a corresponding extension is granted to enable the authorities to invoke and apply consequential remedial assessment provisions; on the facts delay was condoned. en-us Sat, 21 Mar 2026 08:29:07 +0530 Sat, 21 Mar 2026 08:29:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=97955 Filing a refund application within two years under Section 54 is a mandatory statutory limitation that bars the proper officer from entertaining belated claims; the absence of any provision to condone delay means the officer lacks jurisdiction except where the statute permits relief. Where the Act provides no remedy, a writ under Article 226 may be entertained to seek condonation of delay, subject to consideration of laches and bona fides. Any judicial condonation must be conditional: the taxpayer may obtain relief only if a corresponding extension is granted to enable the authorities to invoke and apply consequential remedial assessment provisions; on the facts delay was condoned. Highlights GST Sat, 21 Mar 2026 08:29:07 +0530 https://www.taxtmi.com/highlights?id=97955