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Issues: Whether, for a rebate claim under Section 11B of the Central Excises & Salt Act, 1944, the relevant date is to be excluded while computing the six-month limitation period.
Analysis: The period of limitation had already been settled by the Tribunal to mean that where the statute uses the word "from", the relevant date is excluded and the limitation period begins from the following day. Applying that principle, the rebate claim filed on the sixth month anniversary date could not be treated as time-barred merely because the day of export was excluded from computation.
Conclusion: The claim was within limitation and the Revenue's challenge was rejected.