Limitation for rebate claims is procedural, so an extended filing period can apply to existing export rebate claims.

The right to rebate accrues on export under Rule 12, while Section 11B of the Central Excise Act governs the time for invoking that remedy. An amendment extending the limitation period from six months to one year was treated as procedural and capable of applying to pending or antecedent rebate claims within the enlarged period. Failure to file within the earlier six-month period did not extinguish the substantive rebate right, and the amendment did not impair any vested right of the Revenue. Section 6 of the General Clauses Act did not require a different result. The rejection of the rebate claims as time-barred was therefore unsustainable.

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Issues: Whether the amended period of limitation under Section 11B of the Central Excise Act, 1944 applies to rebate claims arising from exports made before the amendment, and whether failure to file the rebate application within the earlier six-month period extinguishes the substantive right to rebate under Rule 12 of the Central Excise Rules, 1944.

Analysis: The right to rebate accrues on export under Rule 12, while Section 11B prescribes the time within which the remedy is to be invoked. The limitation provision was treated as governing procedure rather than the substantive entitlement to rebate, and therefore its enlargement from six months to one year was held capable of applying to pending or antecedent claims within the expanded temporal window. The Court also held that the amendment did not divest any vested right of the Revenue so as to prevent application of the amended limitation, and that Section 6 of the General Clauses Act, 1897 did not require a contrary result in the circumstances.

Conclusion: The amended one-year limitation applied to the petitioners' rebate claims, and the rejection of the claims as time-barred was unsustainable.

Ratio Decidendi: An amendment extending limitation for rebate claims is procedural in nature and applies to existing claims within the enlarged period, unless the statute clearly manifests a contrary intention; such an amendment does not extinguish the substantive rebate right accruing on export.

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