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Refund Claim Rejection: Procedural Law of Limitation Applies Retrospectively to Ongoing and Future Proceedings for Clarificatory Benefits.
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....Rejection of refund claim - the law of limitation, being a procedural law, is retrospective in operation in the sense that it will also apply to the proceedings pending at the time of enactment as also to the proceedings commenced thereafter, notwithstanding that the cause of action may have arisen before the new provisions came into force - it is clear that any benefit that gets accrued by way of legislation cannot be denied/curtailed, more so, when it is clarificatory in nature like the present one and as such it has to be made retrospective in operation. - HC....