The Delhi High Court held that the amended limitation provision under GST cannot be applied retrospectively, preserving vested rights.
Delhi HC Rules Limitation Amendment Cannot Be Retrospective
The Delhi High Court has ruled that amendments to the limitation provisions under Section 54 of the GST Act cannot be applied retrospectively. This ruling is significant for taxpayers seeking refunds as it preserves their vested rights under prior legislation.
The court clarified that any changes made to the limitation period must not infringe upon rights that taxpayers had accrued under the original wording of the law. As such, all refund claims that were valid under the unamended statute must be considered on their merits.
This decision has far-reaching implications for practitioners handling GST refund claims, reinforcing the principle that legislative changes cannot unfairly disadvantage taxpayers by retroactively altering the timeline for seeking relief. Attorneys should ensure that claims are made within the confines of existing rights and timelines.
Citations
- Delhi HC (2026) Unreported Judgment
