JUDGMENT :

N.V. ANJARIA, J.

1. Heard learned advocate Mr. Dhaval Shah for the petitioner and learned advocate Mr. Priyank Lodha for the respondents.

2. By filing the present petition under Article 226 of the Constitution, the petitioner has prayed for direction against the respondents to re-credit amount of Rs. 3,37,076/- in electronic credit ledger of the petitioner with interest from the date of order dated 19.11.2019 till its realisation. The petitioner has also prayed to set aside the said order dated 19.11.2019.

2.1 By the said order dated 19.11.2019 passed by the Assistant Commissioner, CGST and Central Excise, respondent no. 3 herein, the refund claim of the petitioner came to be rejected on the ground that it was barred by limitation in terms of Explanation (2) (c) (1) of Section 54 of the Central Goods and Services Tax Act, 2017. Further prayer is made to direct the respondents to pay the entire refund claim.

3. The petitioner no. 1 is engaged in the business of trading and clearance of finished excisable goods, namely analytical instruments and consumables such as mass spectroscopy, standard and impurities machinery, laboratory products, force scientific columns, cole parmer,