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Issues: Whether the refund claim was barred by limitation under Rule 11 of the Central Excise Rules.
Analysis: The refund claim based on exemption notifications was distinguishable from cases where entitlement could be determined only at the end of the financial year. Here, the exemption applied to first clearances upto a specified aggregate value, so limitation began from the date of payment of duty on the relevant clearances. The Court therefore rejected the contention that the application could be treated as timely merely because it was filed within six months from the end of the financial year.
Conclusion: The limitation objection under Rule 11 was negatived only to the extent suggested by the petitioners, and the refund claim could not be treated as within time on that footing.