Patna High Court Ruling: GST Refund Limitation Period to Start from Date of Correct Tax Payment

The Patna High Court has ruled that the limitation period for GST refunds, in cases where taxes were paid under the wrong category (e.g., SGST/CGST instead of IGST), must be calculated from the date of correct tax payment. The judgment, delivered by Justices Rajeev Ranjan Prasad and Shailendra Singh, is based on Section 77 of the CGST Act, 2017, Section 19 of the IGST Act, 2017, and CBIC Circular No. 162/18/2021-GST.Sai Steel, a company, had filed its GSTR-01, GSTR-3B, and GSTR-09 returns for the financial year 2017-18 and paid all applicable taxes.