https://www.taxtmi.com/caselaws?id=790277 Under Section 54 of the CGST Act, the relevant date for limitation depends on the category of refund claimed: refund of unutilised input tax credit is governed by Explanation 2(e), which links limitation to the due date for furnishing the return under Section 39, and cannot be treated like export refund under Explanation 2(a). The Delhi HC also held that the amended Explanation 2(e), effective from 1 February 2019, is prospective and cannot retrospectively curtail refund claims arising from earlier periods. Refund rejections as time-barred were set aside, and the applications were directed to be processed on merits in accordance with law. en-us Sat, 18 Apr 2026 00:00:00 +0530 Wed, 22 Apr 2026 08:47:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790277 Under Section 54 of the CGST Act, the relevant date for limitation depends on the category of refund claimed: refund of unutilised input tax credit is governed by Explanation 2(e), which links limitation to the due date for furnishing the return under Section 39, and cannot be treated like export refund under Explanation 2(a). The Delhi HC also held that the amended Explanation 2(e), effective from 1 February 2019, is prospective and cannot retrospectively curtail refund claims arising from earlier periods. Refund rejections as time-barred were set aside, and the applications were directed to be processed on merits in accordance with law. Case-Laws GST Sat, 18 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790277