GST refund limitation: COVID-19 exclusion preserves timely advance-tax refunds, while deficiency-memo corrections relate back to the original application.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....GST refund limitation for tax paid on a taxable advance runs from the tax-payment date, and the COVID-19 exclusion applies where that relevant date falls within the notified excluded period. Applying exclusion of the first day and inclusion of the last day, a payment made on 19 May 2020 permitted filing until 29 February 2024. Rectified applications submitted after deficiency memos relate back only to a timely original application. GST validly paid on a taxable advance is not a deposit outside the statutory refund mechanism, and the two-year filing period is a substantive eligibility condition. Appellate authorities must decide limitation issues with reasons after considering the taxpayer's reply.....