Limitation for refund under self-removal procedure starts with PLA debit; later RT 12 adjustment matters only for additional duty.

Under the self-removal procedure, limitation for a refund claim under Rule 11 runs from the date duty is debited in the Personal Ledger Account on self-assessment, not from the later RT 12 assessment by the proper officer. The later RT 12 scrutiny under Rule 173I is only an arithmetical check on the assessee's self-determined liability; it does not shift the limitation date for the duty already paid. If that later assessment reveals a deficiency, the additional duty arising on adjustment may have its own relevant date. Authorities based on provisional assessment or a different statutory setting were distinguished.

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Issues: Whether, under the self-removal procedure, the period of limitation for refund under Rule 11 commenced from the date of debit entry/payment of duty in the Personal Ledger Account or from the date of assessment of the RT 12 return and adjustment by the proper officer.

Analysis: The reference to "adjustment" in Rule 11 was construed in the setting of the self-removal procedure and the account-current maintained under the rules, not as a reference to provisional assessment under Rule 9B. In the physical control system, payment followed assessment by the proper officer, but under the self-removal procedure the assessee first self-determined the duty under the approved classification and price lists and paid it by debit in the Personal Ledger Account before removal of the goods. The later RT 12 assessment by the proper officer under Rule 173I was treated as a further arithmetical check and, where it disclosed deficiency, only the additional debit arising from that assessment could create a separate reference date for limitation. The cited authorities were distinguished on the ground that they involved provisional assessment or a different statutory setting.

Conclusion: The date of debit entry/payment of duty in the Personal Ledger Account was the relevant starting point for limitation under Rule 11 in the self-removal procedure, and the date of RT 12 assessment was relevant only for any additional duty arising on adjustment.

Ratio Decidendi: Under the self-removal procedure, payment of duty by debit in the Personal Ledger Account on self-determination of liability is the operative date for limitation under Rule 11, while subsequent RT 12 adjustment affects only any further deficiency assessed later.

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