Limitation Under Section 54 for GST Refund - Time Excluded for Deficiency Memo Processing


Last updated: 28 October 2025

Court :
Gujarat High Court

Brief :
The Hon'ble Gujarat High Court in the case of Varidhi Cotspin Private Limited v. Union of India & Ors. [Special Civil Application No. 3595 of 2024, order dated October 07, 2025] held that under Section 54 of the CGST Act, the period between the original refund application and the communication of a deficiency memo (Form GST RFD-03) must be excluded from the limitation period of two years, allowing rectified refund claims within this extended period to be considered as timely filed, provided supportive documentation is submitted.​

Citation :
Special Civil Application No. 3595 of 2024, order dated October 07, 2025

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Bimal Jain
Published in GST
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