Section 104(3) Refund Deadline is Directory; Adjudicating Authority Must Follow Section 11B for Service Tax Refunds.

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....Refund of Service tax - retrospective exemption - The time-limit prescribed u/s 104 (3) is only directory, but however, the time as well as the procedure prescribed u/s 11B applies in full. The Adjudicating Authority is therefore required to grant refund if the refund application is within the time-limit prescribed u/s 11B and not otherwise....