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Issues: (i) Whether the order rejecting the refund claim as a duplicate claim could be sustained without clear reasons; (ii) Whether the refund claim was barred by limitation under section 27(1) of the Customs Act, 1962.
Issue (i): Whether the order rejecting the refund claim as a duplicate claim could be sustained without clear reasons.
Analysis: The appellate order did not disclose whether any earlier refund had in fact been granted or how the present claim was treated as a duplicate claim. In the absence of a reasoned basis, the rejection could not stand.
Conclusion: The rejection on the ground of duplicate claim was unsustainable and was set aside.
Issue (ii): Whether the refund claim was barred by limitation under section 27(1) of the Customs Act, 1962.
Analysis: The refund claim, as modified by the subsequent application, was found to have been made within six months from the date of payment of duty. The finding that the claim was time-barred was therefore erroneous.
Conclusion: The finding that the claim was barred by time was set aside.
Final Conclusion: The matter was remitted for fresh consideration of the refund claim on merits, with directions to examine the supporting documents and pass a reasoned order in accordance with law.
Ratio Decidendi: A refund rejection cannot be sustained on an unsupported duplicate-claim ground, and a claim made within the statutory period cannot be rejected as time-barred.