https://www.taxtmi.com/caselaws?id=788445 Section 54's two year limitation for GST refund claims is mandatory and cannot be treated as directory because allowing extension would subvert the Act's interconnected limitation scheme and remedial timelines. Where the CGST Act contains no statutory mechanism to condone belated refund claims, writ jurisdiction under Article 226 remains available to remedy genuine hardship, subject to principles limiting writ relief. Courts may condone delay in appropriate cases, but any condonation must be case specific, balanced against revenue interests, and accompanied by corresponding enablement for the proper officer to invoke and prosecute related remedial provisions so as not to foreclose statutory rights. en-us Tue, 17 Mar 2026 00:00:00 +0530 Sat, 21 Mar 2026 08:29:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788445 Section 54's two year limitation for GST refund claims is mandatory and cannot be treated as directory because allowing extension would subvert the Act's interconnected limitation scheme and remedial timelines. Where the CGST Act contains no statutory mechanism to condone belated refund claims, writ jurisdiction under Article 226 remains available to remedy genuine hardship, subject to principles limiting writ relief. Courts may condone delay in appropriate cases, but any condonation must be case specific, balanced against revenue interests, and accompanied by corresponding enablement for the proper officer to invoke and prosecute related remedial provisions so as not to foreclose statutory rights. Case-Laws GST Tue, 17 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788445