Limitation for refund claims runs from original filing, so transfer to the correct forum does not make a timely claim time-barred.

A refund claim for Special Additional Duty filed within the prescribed one-year period before the wrong customs refund forum is not time-barred merely because it was later transferred to the correct authority after limitation expired. The date of original filing governs computation of limitation, so rejection solely on the ground of delay was unsustainable. The time-bar objection was rejected, the refund denial was set aside, and the matter was remanded for processing on merits.

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Issues: Whether the refund claim of Special Additional Duty was liable to be rejected as time-barred when it had originally been filed within limitation before the wrong customs refund forum and later transferred to the correct forum.

Analysis: The original refund application was filed within the prescribed one-year period, but before an incorrect refund unit. The date of original filing, and not the date of transfer to the proper authority, was material for computing limitation. A refund claim lodged within time before a wrong forum cannot be treated as barred merely because it was subsequently routed to the correct forum after the limitation period. On that basis, rejection of the refund solely on time-bar was unsustainable.

Conclusion: The time-bar objection was rejected. The refund rejection was set aside and the matter was remanded to the Original Authority for processing the refund claim on merits.

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