High Court Rules Time Limit in Section 27 of Customs Act Doesn't Apply to SAD Refund Claims Under Notification.

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....Refund claim of Special Additional Duty (SAD), under Customs Act, in lieu of sales tax - rejection on the ground of time limitation - The Hon’ble High Court has clearly held that the expression “so far as may be” used in sub-section (6) of Section 3 of CTA, has to be followed to the extent possible. Merely because Section 27 of the Customs Act provides for a period of limitation for filing refund claim, it cannot be held that even for the purposes of claiming refund in terms of the Notification, the same limitation has to be applied. - AT....