Refund application filed on 17.09.2018 within limitation period deemed valid despite deficiency memo. Fresh application a continuation.

The petitioner submitted a refund application within the two-year limitation period for the 2017-2018 year on 17.09.2018. After receiving a deficiency memo, a fresh application was filed on 2.01.2020. The High Court ruled that the original application was valid and within the limitation period, and the subsequent application was a continuation of the first. The order rejecting the refund on limitation grounds was quashed, and the application from 17.09.2018 was reinstated for consideration on its merits by the appropriate officer according to the law. .....

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