Section 11BB refund interest runs from the original application date, even after rejection and remand.

Interest under Section 11BB on a refund sanctioned after remand runs from the expiry of three months after receipt of the original refund application, not from the date of the remand order. The refund claim remained tied to the original application and was not a fresh claim arising from a new determination of duty, valuation, or classification. Earlier rejection did not alter the statutory start date once the claim was ultimately allowed on reconsideration. The stated position is that delayed-refund interest becomes payable after the statutory period from the original application expires, even where the matter has passed through multiple rounds of litigation.

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Issues: Whether interest under Section 11BB is payable from three months after the date of the original rebate or refund application when the claim was initially rejected and later sanctioned after remand.

Analysis: The refund in question arose from the original application filed by the assessee and was not a fresh claim consequent upon a determination of duty, valuation, classification, or similar matter. The remand order did not itself grant refund but only required reconsideration, after which the original claim was sanctioned. In such a situation, the relevant date for computing the three-month period under Section 11BB is the date of receipt of the original refund application, not the date of the appellate remand order. The reasoning accords with the view that interest on delayed refund becomes payable once the statutory period from the original application expires, irrespective of earlier rejection or multiple rounds of litigation.

Conclusion: Interest was payable from three months after the date of the original refund application, and the Revenue's challenge to that entitlement failed.

Ratio Decidendi: Where a refund claim is ultimately sanctioned on the basis of the original application, interest under Section 11BB runs from the expiry of three months after receipt of that application, even if the claim was earlier rejected and later allowed after remand.

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