2025 (11) TMI 1931

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....ce S.R. Krishna Kumar For the Petitioner : Sri. Ganesh V. Shandage, Advocate For the Respondents : Sri. Chandrashekar, Cgsc For R1, Sri. Aravind V. Chavan, Advocate For Ro2 To R5 And Sri. Madhu N. Rao, Advocate For R6 ORAL ORDER In this petition, petitioner seeks for the following reliefs:- "a) Issue a Writ of Certiorari, or such other Writ, Order or direction in the nature of a Writ of Certiorari, quashing the impugned 3(Three) deficiency notes in FORM GST RFD-03 dated 18.05.2023 (Bearing Reference No. ZE2905230288486), 05.07.2023 (Bearing Reference No.-) and 14.12.2023 (Bearing Reference No.-) issued by Respondent No.4 under Rule 90(3) of the Central Goods and Services Rules, 2017 (Annexure - R1, Annexure R2 and Annex....

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....r may be directed to be considered as if the same was filed on 03.05.2023 on which date the petitioner filed the first refund application and to dispose of and pass appropriate orders on the fresh/new refund application to be filed by the petitioner including the claim for interest put forth by the petitioner. 5. Per contra, learned counsel for the respondents on instructions submits that if the petitioner files a fresh/new refund application along with supporting documents, the concerned respondents shall consider the refund application in accordance with law without reference to the period of limitation and by treating the fresh/new application as if it was filed on 03.05.2023 which was the date of filing the first refund application a....