SETHI SONS Vs. ASSISTANT COMMISSIONER

JUDGEMENT

(1.) The petitioner has filed the present petition, essentially, aggrieved by the denial of refund of unutilised input tax credit (ITC) accumulated in respect of the Goods and Services Tax paid on inputs in respect of the zero-rated supplies ' goods exported without payment of Integrated Goods and Services tax (IGST) ' during the period from July 2017 to March 2018.

(2.) The petitioner impugns an Order-in-Original dtd. 11/3/2020 whereby the Proper Officer rejected the petitioner's application for refund on the ground that it was filed beyond the period of two years as specified under Sec. 54(1) of the Central Goods and Services Tax Act, 2017 (hereafter 'the CGST Act").

(3.) The petitioner appealed the said decision before the Appellate Authority, but was unsuccessful. The petitioner's appeal was rejected by an Order-in-Appeal dtd. 6/8/2021, which is also impugned in the present petition. The orders dtd. 11/3/2020 and 6/8/2021 are hereafter referred to as 'the impugned orders'.