Where refund is claimed for unutilised input tax credit on exports or inverted duty structure pertaining to the pre-amendment period, the relevant date under Section 54 of the CGST Act is governed by unamended Explanation 2(e) and not Explanation 2(a), and the 2019 amendment cannot retrospectively curtail the limitation period – Kanika Exports Vs. Union of India and Ors. – Delhi High Court
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