The Hon’ble Karnataka High Court in the case of Assistant Commissioner of Central Taxes & Ors. v. Merck Life Science Pvt. Ltd. [Writ Appeal No. 110 OF 2026 and Ors, order dated March 17, 2026] held that the two-year limitation period under Section 54 of the CGST Act for filing refund claims is mandatory; however, in deserving cases, delay may be condoned only through exercise of writ jurisdiction under Article 226, subject to conditions ensuring parity with statutory timelines.
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