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Issues: Whether interest on refund was payable from three months after the original refund application or only from a later revised claim, and whether Section 11BB of the Central Excise Act, 1944 applied to a refund claim relating to a period prior to its insertion.
Analysis: The refund application was filed after the introduction of Section 11BB, and the statutory expression governing interest is tied to the receipt of the application for refund. The later revision of the claim did not displace the original filing date for the purpose of computing interest. The provision was held applicable to applications filed after its commencement, even if the underlying duty period was earlier.
Conclusion: Interest was correctly directed to be computed from three months after the dates of receipt of the refund applications, and Section 11BB applied to the claim. The Revenue's challenge failed.
Final Conclusion: The order granting interest on the refund claim was upheld and the Revenue's appeal was rejected.
Ratio Decidendi: Interest under Section 11BB of the Central Excise Act, 1944 is to be computed from three months after receipt of the refund application, and the provision applies to refund applications filed after its insertion even if they relate to an earlier duty period.