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Issues: Whether interest on the refunded excise duty amount was payable from the date of the refund application or only from the date of the writ court's refund order.
Analysis: The refund application was made long after the last payment of duty and was clearly barred by time. The refund could be granted only in exercise of writ jurisdiction under Article 226 of the Constitution of India. In those circumstances, the award of interest could not run from the date of the belated refund application and was confined to the date of the refund order.
Conclusion: Interest was not payable from the date of the refund application; it was payable only from the date of the order granting refund, and the direction granting earlier interest was modified accordingly, in favour of the Revenue.