JUDGMENT

Vibhu Bakhru, J. - Issue notice.

2. The learned counsel for the respondents accept notice.

3. The petitioner has filed the present petition impugning orders dated 28.01.2022 and 21.06.2023.

4. The petitioner is essentially aggrieved by the denial of refund of its unutilised Input Tax Credit (hereafter `ITC') in respect of zero-rated supplies.

5. The petitioner had filed an application on 28.11.2021, seeking refund of the unutilised ITC of a sum of Rs.9,45,816/- (Rs.4,72,908/- under the Central Goods and Services Tax Act, 2017 and Rs.4,72,908/- under the State Goods and Services Tax Act, 2017), for the period from April, 2018 to March, 2019.

6. The petitioner's application was acknowledged by the concerned authorities on 30.12.2021 by issuing requisite form (GST-RFD-02). Thereafter, on the same date, the concerned authorities issued a Show Cause Notice (hereafter `SCN') in Form GST-RFD-08, proposing to reject the petitioner's application as being barred by time.

7. According to the concerned authorities, the petitioner's application was not filed within the stipulated period of two years from the relevant date as required under Section 54(1) of the Central Goods and Services Tax A