Petitioner seeks GST refund after service tax notifications declared ultra vires; dispute over when limitation period began

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....The HC observed that notifications imposing GST on specified services were declared ultra vires and that the petitioner sought refund of tax paid following finality of that declaration. The revenue refused the refund on limitation grounds, contending the limitation period commenced from the Supreme Court's order dated 19.05.2022. Noting the dispute as to the temporal commencement of limitation and the petitioner's entitlement to restitution, the HC issued notice to the respondent to answer the claim for refund, returnable 3 October 2025, thereby directing adjudication of the limitation defence and the petitioner's refund claim on the merits.....