Case Law Analysis
|Karnataka High Court
Section 54 CGST Act | Two-Year Refund Limit Mandatory, But Writ Jurisdiction Under Article 226 Can Condone Genuine Delay : Karnataka HC
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.