The three month gap is mandatory after issuance of notice under section 73(2) of CGST Act, and the final order is to be passed after the mandatory period.

SEZ Approval Committee has approved services like Rent-a-Cab, Outdoor Catering, CHA services and Security services as authorised services, refund cannot be denied merely because the department considers them unrelated to manufacturing.

The Tribunal emphasised that statutory procedures must be followed strictly and cannot be waived casually.