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* IN THE HIGH COURT OF DELHI AT NEW DELHI Reserved on: 20^th December, 2025 Pronounced on: 18^th April, 2026 Uploaded on: 18^th April, 2026 + W.P.(C) 12512/2021 M/S KANIKA EXPORTS .....Petitioner Through: Mr. N.K. Sharma & Mr. Deepak Gautam, Advs.

Mr. Rakesh Kumar, Adv.

versus UNION OF INDIA & ORS. .....Respondents Through: Mr. Aditya Singla SSC CBIC with Ms.

Arya Suresh Nair, Adv.

Mr. Virender Pratap Singh Charak, Ms. Shubhra Parashar & Ms. Priya Shukla, Advs.

+ W.P.(C) 17538/2022 M/S MALIK SEASONING AND SPICES PRIVATE LIMITED .....Petitioner Through: Mr. Tarun Gulati, Sr. Adv. with Mr.

Dinesh Parashar, Advs.

Mr. Rakesh Kumar, Adv.

versus COMMISSIONER OF GOODS AND SERVICE TAX.....Respondent Through: Mr. Aditya Singla SSC CBIC with Ms.

Arya Suresh Nair, Adv.

CORAM:

JUSTICE PRATHIBA M. SINGH JUSTICE SHAIL JAIN

JUDGMENT

Prathiba M. Singh, J.

1. This hearing has been done through hybrid mode

2. The question that has arisen in these petitions is whether the Petitioners’ refund applications were filed within the prescribed period of limitation or not. Although at first glance, the issue appears to be quite simple, it has been rendered complex due to various interlinked and interconnected provisions,