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2022 (6) TMI 708 - MADHYA PRADESH HIGH COURTInterest on delayed refund - Extended Period of limitation - refund having been made beyond the period of three months from the date of filing of application for refund - Section 6 of the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 and section 11BB of the Central Excise Act, 1944 - HELD THAT:- From bare perusal of Section 6 of the 2020 Act, it is evident that the time limit as and where prescribed in the provisions of Central Excise Act, 1944 is deemed to be extended without any exception. Thus, the time limit prescribed in Section 11BB of the Central Excise Act is deemed to be extended by Section 6 of the 2020 Act. As such, in view of the overriding effect of Section 6 of the 2020 Act, the time limit of three months prescribed for grant of refund u/s 11BB also stands extended till 30th September, 2020. The order of refund was passed within the extended time limit and, therefore, is saved by Section 6 of the 2020 Act from being subjected to the rigors of Section 11BB of Central Excise Act - It is well settled that Tax Laws are to be interpreted strictly in terms of the terminology employed by legislature. Nothing can be inferred nor implied. Tax statute is to be plainly read without bringing the element of equity into play. Thus, the refund was sanctioned within extended time period prescribed under the 2020 Act and, therefore, the claim for interest in that regard is untenable and thus is hereby rejected - petition dismissed.
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