Refund Claim Upheld: Arbitrary Filing Date Restriction Invalidated, Statutory Two-Year Limitation Period Preserved for Input Tax Credit

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....HC ruled that the petitioner's refund claim for accumulated ITC was improperly rejected. Applying precedent from Patanjali case, the court held that filing a refund application after 18.07.2022 does not automatically disqualify an applicant from seeking refund within the statutory two-year limitation period. The notification creating an arbitrary classification among assessees based on filing date was deemed invalid. Consequently, the court quashed the rejection orders dated 24.02.2023 and 30.01.2023, thereby allowing the petitioner's refund claim and upholding the statutory right to file claims within the prescribed time limit.....