Refund limitation under exemption notifications runs from duty payment, not financial year-end, under Section 11B explanation.

Refund claims based on exemption notifications linked to clearances during a financial year are governed by Explanation (f) to Section 11B of the Central Excises and Salt Act, 1944, so the limitation period runs from the date of payment of duty. The Tribunal relied on its earlier Larger Bench view and rejected the argument that time should start from the end of the financial year. The operative effect is that refund applications must be filed within the statutory period counted from duty payment, not year-end.

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Issues: Whether the limitation period for refund claims based on exemption notifications commences from the date of payment of duty or from the end of the financial year.

Analysis: The issue had already been authoritatively decided by the Tribunal in an earlier Larger Bench decision, which held that refund claims founded on exemption notifications linked to clearances during a financial year are governed by Explanation (f) to Section 11B of the Central Excises and Salt Act, 1944. On that basis, the relevant time limit begins from the date of payment of duty.

Conclusion: The limitation period commences from the date of payment of duty and not from the end of the financial year.

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