Time limit for refund scrutiny bars post period deficiency memos, requiring sanction of the refund with statutory interest.

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....Failure to comply with statutory timelines for refund scrutiny means issuance of a deficiency memo after the prescribed period is impermissible, so the refund claim must be processed and allowed in accordance with the applicable acknowledgement and scrutiny rules; the prior direction to sanction refund with statutory interest therefore remains operative and requires enforcement. The writ seeking mandamus for compliance was allowed, directing the respondent to sanction the refund for the specified period together with statutory interest and to complete compliance within the time directed by the Court.....