Limitation for excise interest follows the principal demand when interest is claimed as an adjunct to that recovery.

Interest claimed as an adjunct to a principal excise demand was treated as subject to the same limitation principle governing recovery of the principal amount. The Tribunal's approach, that the limitation applicable to the main demand also governs the interest claim, was not disturbed by the Bombay HC, which declined to interfere with the revenue's challenge. The practical effect is that recovery of interest under the Central Excise Act may be time-barred on the same footing as recovery of the underlying demand when the interest claim is ancillary to that demand.

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Issues: Whether the time limit applicable to recovery of the principal amount also governs recovery of interest under the Central Excise Act.

Analysis: The Tribunal's view was based on the principle that the limitation applicable to the principal demand should equally apply to the interest claim. The Court found no reason to interfere with that approach and, on that basis, declined to entertain the revenue's challenge.

Conclusion: The limitation period for recovery of interest was treated as applicable on the same footing as the principal demand, and the revenue's appeal failed.

Ratio Decidendi: Where interest is claimed as an adjunct to the principal excise demand, the same limitation principle applies to the recovery of interest.

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