SUMMARY: The petitioners were directed to file a fresh substantive application seeking re-credit of the excess duty paid, holding that the rejection of a time-barred rebate claim does not preclude an assessee from seeking the return of excess duty under Section 142(3) of the CGST Act.

The Tribunal held that the appellant was not an 'undersized business entity' eligible for the exemption.

The move aims to ensure fair participation and equal tax treatment for all investors under the revised framework.