Statutory limitation bars refund claims before fiscal authorities when the claim is filed after the prescribed period.

Refund claims made before fiscal authorities must comply strictly with the limitation period prescribed by the statute, because departmental powers are confined to the statutory scheme and cannot be used to grant refund beyond that bar. The Limitation Act was not treated as enlarging the authority's power to allow an otherwise time-barred refund claim. The export cess refund claim, having been filed after expiry of the prescribed period, was therefore barred by limitation and could not be allowed.

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Issues: Whether refund of export cess claimed beyond the prescribed period of limitation could be allowed, and whether the Limitation Act applied to permit such refund.

Analysis: The claim for refund was made after expiry of the limitation period. The Court applied the principle that departmental authorities exercising powers under the fiscal statute are confined to the statutory scheme and cannot grant refund beyond the period prescribed by the statute. Reliance was placed on the Supreme Court's view that, where a refund claim is made before the department, the limitation provided by the statute must be strictly followed, and any broader remedy for money paid under mistake lies elsewhere and not by disregarding the statutory bar.

Conclusion: The refund claim was barred by limitation and could not be allowed.

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