Refund limitation under Chapter X fails where goods were received on duty payment, not under the prescribed procedure.

Refund claims for goods received on payment of duty cannot be treated as claims arising under Chapter X merely because the goods could have been procured under that procedure without duty. As the refund did not stem from compliance with Chapter X, the special time-limit exemption was unavailable, and the ordinary limitation period applied. Authorities cited by the claimant were found irrelevant on these facts. The refund claim was therefore time-barred and its rejection was upheld.

---

---

Issues: Whether the refund claim was barred by limitation where the goods were received on payment of duty and not under Chapter X procedure.

Analysis: The refund did not arise from compliance with Chapter X procedure. The goods were received on payment of duty, even though they could have been obtained under Chapter X without payment of duty. In these circumstances, the claim could not be treated as one arising under Chapter X, and the time limit was not rendered inapplicable. The authorities relied on by the appellant were held to be irrelevant on these facts.

Conclusion: The refund claim was hit by limitation and its rejection was upheld.

---