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Issues: Whether the petitioners were entitled to refund of the advance duty paid under the compounded levy scheme, and whether the claim was barred by limitation.
Analysis: The advance duty had been paid prior to the withdrawal of the compounded levy scheme, and once that scheme ceased, the payment was no longer to be treated as excise duty in the same manner. The amount ought to have been returned or adjusted against duty payable under the normal procedure. The payment was treated as a case of double payment, and any computation of limitation was considered with reference to the finalisation of RT-12 rather than the earlier date relied upon by the lower authority.
Conclusion: The refund claim was not time-barred and the petitioners were held entitled to refund.
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