GSTAT holds Rule 89(5) Amendment Applies Retrospectively to Refund Claims

The dispute concerned inverted-duty refunds where the Department sought to deny the differential refund by applying the pre-amendment formula and other restrictions. Following Ascent Meditech and the Supreme Court's dismissal of the Department's SLP, GSTAT held that the amended formula can operate retrospectively and that there is no bar to filing a supplementary refund claim within the Section 54 limitation period.