Interest on delayed excise refund starts from a valid refund application, not later verification of already filed documents.

A valid refund application under Section 11B of the Central Excise Act must be in the prescribed form and supported by documents showing duty payment and that the incidence was not passed on. Where those core documents were already filed, later requirements for correlation of chassis and engine numbers from existing records or additional certification did not render the applications incomplete from inception. Interest under Section 11BB becomes payable if the sanctioned refund is not made within three months of receipt of a valid Section 11B application, and the starting point is not postponed by later verification exercises. The denial of interest was therefore unsustainable.

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Issues: Whether the petitioner was entitled to interest under Section 11BB of the Central Excise Act on delayed refund, and whether the refund applications could be treated as incomplete so as to postpone the starting point for interest.

Analysis: Section 11B requires a refund claim to be made in the prescribed form with supporting documents establishing payment of duty and non-passing of incidence. Section 11BB fastens interest liability if refund ordered under Section 11B(2) is not made within three months from receipt of the application under Section 11B(1). On the record, the necessary duty payment documents were already filed, and the appellate authority had only required correlation of chassis and engine numbers from the existing documents and additional certification to reinforce that correlation. The revisional view that the applications were incomplete from inception was inconsistent with the record and the earlier appellate findings.

Conclusion: The applications were valid refund applications under Section 11B, and the petitioner was entitled to interest under Section 11BB from the expiry of three months after receipt of those applications. The denial of interest was unsustainable.

Ratio Decidendi: Interest under Section 11BB becomes payable when a valid refund application under Section 11B is not refunded within three months of its receipt, and the starting point is not deferred merely because further verification or correlation of already filed documents is later required.

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