https://www.taxtmi.com/caselaws?id=802177 GST refund limitation excludes 1 March 2020 to 28 February 2022 under Notification 13/2022-Central Tax. Where the relevant tax payment date fell within that period, the full two-year limit ran from 1 March 2022 to 29 February 2024, making an application filed on the last day timely. An application rectified in good faith after a deficiency memo relates back to a timely original filing but cannot cure a late original claim. GST paid on a taxable advance remains subject to the refund framework even if the corresponding supply does not materialise; it cannot be reclassified as a deposit to avoid limitation. The statutory time limit is a substantive eligibility condition that procedural circulars cannot relax. Non-consideration of a show-cause reply vitiates rejection, but appellate authorities must decide disputed points with reasons. A challenge to limitation calculations on admitted facts introduces no new charge if limitation was raised in the notice. en-us Thu, 29 Oct 2026 00:00:00 +0530 Mon, 02 Nov 2026 08:31:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=802177 GST refund limitation excludes 1 March 2020 to 28 February 2022 under Notification 13/2022-Central Tax. Where the relevant tax payment date fell within that period, the full two-year limit ran from 1 March 2022 to 29 February 2024, making an application filed on the last day timely. An application rectified in good faith after a deficiency memo relates back to a timely original filing but cannot cure a late original claim. GST paid on a taxable advance remains subject to the refund framework even if the corresponding supply does not materialise; it cannot be reclassified as a deposit to avoid limitation. The statutory time limit is a substantive eligibility condition that procedural circulars cannot relax. Non-consideration of a show-cause reply vitiates rejection, but appellate authorities must decide disputed points with reasons. A challenge to limitation calculations on admitted facts introduces no new charge if limitation was raised in the notice. Case-Laws GST Thu, 29 Oct 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=802177