Circular no. 125/44/2019-GST not apply to manually filed refund application

C.P. Ravindranath Menon Vs Union of India (Bombay High Court) Held that Circular No. 125/44/2019-GST dated 18th November 2019 shall be applicable only to applications filed electronically on the common portal but would have no applicability to an application for refund which is filed manually. It further held that Revenue cannot raise new arguments at appellate stage when earlier rejection of refund was on different ground altogether. Facts- By this Petition filed under Article 226 of the Constitution of India, the Petitioner has impugned the Order dated 18th February 2021 passed by the Respon...