Under Section 54 of the CGST Act, the two-year period for refund is mandatory for the proper officer, but in the absence of any statutory mechanism for condonation, delayed refund claims may be entertained under Article 226 with corresponding extension to the Revenue to invoke Sections 73 and 74 – Assistant Commissioner of Central Taxes North West Division -1, North West Commissionerate and Ors. Vs. Merck Life Science Pvt. Ltd. – Karnataka High Court