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    <title>2026 (3) TMI 1445 - CESTAT ALLAHABAD</title>
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    <description>Section 142(3) of the CGST Act preserves only refund claims that were already maintainable under the existing law and does not create a fresh cash-refund right where none existed earlier. Applying that transitional framework, the refund linked to the 09.05.2019 payment was governed by the limitation under Section 11B of the Central Excise Act, with the relevant date being the date of payment; the one-year period had already expired before the COVID exclusion period began, so the claim remained time-barred. The alternative refund routes based on export-related theory and Rule 5 of the Cenvat Credit Rules were also found inapplicable.</description>
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