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Issues: Whether interest on the refunded excise duty was payable at 18% per annum, and from what date such interest should run.
Analysis: The award of interest on the refunded amount was upheld as justified and the rate of 18% per annum was found reasonable. However, the commencement date for interest was confined to the date of the Tribunal's order, since the respondent's entitlement to refund arose only from that order. The period prior to the Tribunal's decision was not accepted as the proper basis for interest.
Conclusion: Interest at 18% per annum on the refunded principal amount was payable only from 20-9-1990 until 27-8-1991.