Late Refund Claim for Residential Complex Services Denied u/s 102 of Finance Act 1994 Due to Late Filing.

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....Rejection of refund claim - residential complex services - Section 102 of Finance Act, 1994 - In the instant case, the refund claim was not filed within a period of six months as provided in sub Section (3) of Section 102 of Finance Act, 1994. The Finance Bill was granted assent on 14.05.2016. Refund claim has been filed on 05.09.2017. - The exemption was revived by notification dated 01/03/2016. But since it was prospective in effect, the appellant was not entitled for any exemption, which the appellant was aware of and with open mind and eyes deposited the service tax due with interest. - AT....