Courts have held that the two-year limit under Section 54 is not mandatory in all cases. Where the refund claim is genuine, bonafide, and causes no revenue loss, procedural delay cannot defeat substantive rights.
The issue was whether GST applies on amounts deducted as “royalty” from contractors’ bills. It was held that such deductions do not constitute taxable supply and cannot attract GST.
Examines how courts scrutinized GST arrests and bail where tax evasion was inflated through extrapolation. Key takeaway: evidence-based figures matter more than assumptions.