Tax Refund Denied for Late Filing u/s 54(1); Credit Notes Could Have Offset Excess GST Payment.

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....Refund claim - time limitation - it is claimed that tax was paid by mistake on account of non-supply of any service either wholly or partially - The option available to the petitioner was to request its customer/client to issue an appropriate credit notes to neutrilize the alleged excess payment of GST while generating and issuing invoices dated 01.11.2017 details of which was captured in their regular return and tax was paid - refund claim filed by the petitioner is clearly barred under the limitation prescribed u/s 54(1) of the respective enactments read with explanation (h). - HC....