#Refund Limitation

Madras High Court rules that refund claims for duties paid under protest while an appeal is pending with a stay order are exempt from the one-year limitation under Section 11B. The judgment clarifies that appropriation of rebate during litigation does not constitute voluntary payment, preserving assessees' refund rights even after appellate success.

Karnataka High Court rules that while Section 54 of the CGST Act imposes a strict two-year deadline for refund claims, taxpayers may seek relief under Article 226 writ jurisdiction if delays are justified. The court emphasized that authorities must be granted reciprocal time to invoke Sections 73 or 74, balancing taxpayer rights with revenue protection.