Refund limitation under an exemption notification runs from the date the post-clearance condition is satisfied, not duty payment.

Refund entitlement under Notification No. 12/2012-CE arose only when the purchaser produced proof that the vehicle had been registered for sole use as a taxi or ambulance, so the manufacturer's right to refund did not crystallise at the time duty was paid on clearance. The six-month limitation in Condition No. 26(b) was therefore computed from the date of such registration, not from the earlier duty payment date. On that basis, a refund application filed within six months of registration was within time.

---

---

Issues: Whether the six-month period for claiming refund under Notification No. 12/2012-CE commenced from the date of payment of duty or from the date on which the vehicle was registered for use as a taxi or ambulance.

Analysis: The refund entitlement under the notification arose only when the purchaser produced proof that the vehicle had been registered for sole use as a taxi or ambulance. Until that event occurred, the manufacturer's right to claim refund had not crystallised. The limitation prescribed in Condition No. 26(b) was therefore to be computed from the date of such registration, not from the earlier date of duty payment at clearance.

Conclusion: The six-month limitation was to run from the date of registration of the vehicle as a taxi or ambulance, and the refund claim filed within that period was within time.

Ratio Decidendi: Where a refund under an exemption notification becomes claimable only upon fulfillment of a subsequent stipulated condition, limitation for filing the refund application begins from the date on which that condition is satisfied and the right to refund crystallises.

---