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2022 (10) TMI 1006 - GUJARAT HIGH COURTInterpretation of statute - interpretation of mandatory time limit to file refund claim prescribed in clause (e) of the Para 3(III) of the Notification No.12/2013-ST dated 01.07.2013 issued by the Government of India, Ministry of Finance, Department of Revenue - right to hold and interpret that the mandatory condition of the Notification that the SEZ unit shall submit only one claim of refund for every quarter, can also include refund claim pertaining to invoices of previous quarters as well, i.e. consolidated invoices of period from August 2013 to October 2017, which is a a complete misreading of clause (f) of Para III of Notification No.12/2013- ST dated 01.07.2013. HELD THAT:- This court is of the view that the appeal deserves Admission on the substantial questions of law - Application disposed off.
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