Input duty credit refund linked to reversed proforma credit was outside unjust enrichment under excise law.

Refund arising from reversal of proforma input duty credit under Rule 56A was treated as a credit adjustment claim, not as a cash duty refund simpliciter. Because the refund amount exactly matched the reversed credit and the claim followed the legal position that simultaneous availment of Rule 56A and Rule 57A credit for different final products was permissible, the claim was linked to input duty credit rather than to an excess duty payment. On that basis, the bar of unjust enrichment under Section 11B(2) did not apply, and the Revenue's objection was correctly rejected.

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Issues: Whether the refund claim represented reversal of input duty credit under Rule 56A of the Central Excise Rules, 1944, and was therefore outside the bar of unjust enrichment under Section 11B(2) of the Central Excise Act, 1944.

Analysis: The refund arose from the assessee's reversal of proforma credit availed under Rule 56A after the High Court held that simultaneous availment of Rule 56A credit and Rule 57A credit for different final products was permissible. The amount claimed exactly matched the credit reversed, and the sequence of events showed that the claim was not a cash duty refund simpliciter but a claim linked to input duty credit. On that basis, the bar of unjust enrichment was not attracted.

Conclusion: The refund claim was rightly treated as one relating to input duty credit, and the rejection of the Revenue's objection was correct.

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