Refund limitation turns on the original debit date, not an unauthorised later entry that merely reverses a credit.

For refund limitation purposes, the original debit in the personal ledger account was treated as the relevant date, because the later debit and reversal were made unilaterally by the assessee without authority and only to neutralise an intervening credit entry. The later entry did not reset the limitation period. Applying that date, the refund application filed thereafter was beyond time and was rejected as time-barred.

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Issues: Whether the refund claim of duty was barred by limitation, and whether the later debit entry could be treated as the relevant date for computing limitation.

Analysis: The duty had been initially debited in the personal ledger account on 15-7-1999. The subsequent reversal of that debit, followed by another debit on 10-2-2000, was made by the assessee on its own and without authority. For limitation, the relevant date remained the original debit dated 15-7-1999, and not the later debit entered only to neutralize the intervening credit entry. On that basis, the refund application filed on 14-2-2000 was beyond time.

Conclusion: The refund claim was time-barred and was rightly rejected.

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