Refund limitation under Section 11B runs from duty payment, not financial-year end, for exemption-linked claims.

For refund claims linked to exemption notifications measured by aggregate clearances in a financial year, limitation under Section 11B runs from the date of payment of duty because Explanation (f) supplies that default relevant date where no special rule applies. The close of the financial year does not postpone the statutory commencement of limitation, and the accrual of a cause of action or equitable hardship cannot override the text of the provision. Refund claims filed beyond six months from payment were therefore time-barred.

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Issues: Whether, for refund claims based on exemption notifications tied to the value or quantity of clearances during a financial year, the relevant date for limitation under Section 11B of the Central Excise Act, 1944 is the date of payment of duty or the close of the financial year.

Analysis: The refund claims arose from duty paid on clearances made during the financial year, with entitlement to exemption depending on the aggregate clearances remaining within the prescribed ceiling. The Tribunal examined conflicting High Court and Tribunal decisions and the text of Section 11B, including Explanation (f), which provides that in any case not otherwise covered the relevant date is the date of payment of duty. The provision does not create a special rule making the close of the financial year the relevant date for refund claims of this kind. The Tribunal held that the date of accrual of a cause of action is irrelevant for computing limitation under Section 11B and that equitable hardship cannot override the statutory language governing limitation.

Conclusion: The relevant date is the date of payment of duty, not the close of the financial year, and the refund claims filed beyond six months from payment were time-barred.

Final Conclusion: The revenue authorities were entitled to succeed because refund claims founded on such exemption notifications remain subject to the ordinary limitation period under Section 11B, computed from payment of duty.

Ratio Decidendi: Where Section 11B does not specify a different relevant date for a category of refund claim, limitation runs from the date of payment of duty under Explanation (f), and a financial-year-based entitlement to exemption does not postpone that statutory commencement of limitation.

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