GST refund limitation permits writ-based delay condonation where double reversal of transitional credit requires statutory reconsideration.
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....GST refund applications remain subject to a mandatory two-year limitation period, but writ jurisdiction may be available to condone delay. An asserted double reversal of TRAN-I credit, discovered only on examining records, can constitute just cause for such condonation. The time-bar rejection was set aside, and the refund claim was restored for fresh examination by the statutory authority upon production of supporting documents.....
TaxTMI