2025 (11) TMI 427

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....Mr. Manish Upadhye, AGP. For the Respondent Nos.1 & 3: Mr. J. B. Mishra a/w Harshad Shingnapurkar, Soutrik Kar, Rupesh Dubey and Ashutosh Mishra. P.C.:- 1. Heard learned counsel for the parties. 2. Rule. The rule is made returnable immediately at the request of and with the consent of learned counsel for the parties. 3. The Petitioner, inter alia, challenges orders dated 23 June 202....

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....ation and not from the date of filing of a subsequent application after clearing the deficiencies pointed out in the original application. Mr Bapat submitted that several other High Courts have also taken a similar view in the context of the provision of Rule 90(3) of the CGST and SGST Rules. Mr Bapat submitted that this would be the most reasonable manner to construe Rule 90(3), because otherwise....

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....ice would be met if the impugned orders dated 23 June 2020 and 18 August 2021 are set aside and directions are issued to the proper officer to decide the Petitioner's application for refund afresh after considering the decision of the Gujarat High Court and such other decisions as the Petitioner may choose to rely in the context of the limitation issue. 8. The proper officer must dispose of the....