TMI Blog2023 (5) TMI 1232X X X X Extracts X X X X X X X X Extracts X X X X ..... it was time-barred - HELD THAT:- It is stated that in the present case, the zero-rated supplies are stated to have been made between August 2017 to March 2018. According to the petitioner, the refund in respect of the supplies made during the period of February 2018 to March 2018, is within the period of limitation; if the period after 01.03.2020 to 28.02.2022, is excluded - It is apparent that n ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Adjudicating Authority [Assistant Commissioner of Central Goods Services Tax], rejecting the petitioner s claim for refund. The petitioner also impugns the order dated 25.02.2022, passed by the Appellate Authority [Commissioner of Central Goods and Service Tax/GST(Appeals-1)], whereby the petitioner s claim for refund of Input Tax Credit (ITC) pertaining to the goods supplied to SEZ Units (zero- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... at it was time-barred. The petitioner s request for condonation of delay on account of mitigating circumstances resulting from the outbreak of Covid 19 was not accepted. 3. By the impugned order dated 26.05.2021, the Adjudicating Authority rejected the petitioner s application for refund of an amount of ₹13,43,719/- as it was beyond the period of two years as stipulated under Section 54(1 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on; if the period after 01.03.2020 to 28.02.2022, is excluded. 7. The learned counsel also submits that as far as the refund for the supplies made during August 2017 to January 2018 is concerned, the question whether the same is barred by limitation, is required to be considered with reference to a due date for filing the returns for the said period. 8. It is apparent that neither the Adjudi ..... X X X X Extracts X X X X X X X X Extracts X X X X
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