Separate excise unit protests do not carry over to another factory; Board tariff advice does not trigger section 11B(3) refund relief.

Separate excise units must comply independently with classification, assessment, duty payment and refund procedures. A protest lodged for duty paid at one factory does not extend to another factory operating under a separate excise licence, so it cannot preserve limitation for that other unit's refund claim. Section 11B(3) applies only where refund arises from an order in appeal or revision under the Act; a tariff advice issued by the Board is merely administrative and is not equivalent to such an order. On that basis, the refund claim was time-barred and could be rejected.

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Issues: Whether a protest lodged in respect of duty payments at one factory could extend to duty payments at another factory operating under a separate excise licence, and whether a tariff advice issued by the Board could attract the refund mechanism under section 11B(3).

Analysis: The two factories were required to comply separately with excise law, including classification, assessment, duty payment and refund claims. A protest, if intended to save a refund claim from limitation, had to be lodged in respect of the relevant unit and payment. The protest filed for the Virudhunagar factory could not automatically govern duty paid at the Coimbatore factory. Section 11B(3) applied only where refund became due as a result of an order in appeal or revision under the Act. A tariff advice issued by the Board was only an administrative act and was not equivalent to an appellate or revisional order. The relied-upon precedent was found inapplicable on its facts.

Conclusion: The protest for the Virudhunagar factory was not available for the Coimbatore factory, and section 11B(3) did not apply. The refund claim was time-barred and was rightly rejected.

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