Rule 117(1) Challenge Dismissed: Time Limit on Duty and Credit Claims to Stay Under CGST and GGST Rules.

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....The claims of carry forward of the existing duties and credits during the period of migration, therefore, had to be within the prescribed time. Doing away with the time limit for making declarations could give rise to multiple large­scale claims trickling in for years together, after the new tax structure is put in place - there is no substance in the petitioners’ challenge to rule 117 (1) of the CGST Rules as well as GGST Rules.....