Consequential GST refund rejection requires statutory appeal where fresh lawful grounds remain open after appellate remand.

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....A consequential GST refund rejection following an appellate order may be challenged through the statutory appeal where the appellate order merely set aside the earlier rejection on previously considered grounds. The Proper Officer may examine refund entitlement afresh on other legally permissible grounds, provided the fresh reasons are distinct from those rejected in appeal. Questions concerning the appellate order's effect and the validity of the new rejection grounds require merits review in the statutory appellate process. Writ intervention is unavailable where the order is not prima facie non est or wholly without jurisdiction. The taxpayer may seek exclusion of the time spent in writ proceedings for limitation purposes.....