The dispute concerned whether the two-year limit under Section 54 is mandatory. The Court ruled it is directory and cannot defeat legitimate refund claims. The takeaway is flexible interpretation in deserving cases.
Explore interpretation of Section 281B(2) of Income Tax Act, 1961 regarding power of extension of provisional attachment and role of authorized officers.
Understand the relevance of statements recorded under Section 70 of the CGST Act in adjudication proceedings. Explore the provisions of the Act and the distinction between prosecution proceedings and adjudication proceedings.
