Delayed refund interest under Customs law follows successive notifications during continuing delay, not one fixed rate throughout.

Under Section 27A of the Customs Act, the rate of interest on delayed refund continues to track successive Central Government notifications during the period of continuing delay. The phrase "for the time being fixed" was read as applying to each stage after the statutory refund period expires, so later notifications govern the relevant later periods rather than only the first default date. A construction fixing one uniform rate for the entire delay would make subsequent notifications redundant. The appellate authority's uniform-rate approach was therefore not sustainable.

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Issues: Whether, under Section 27A of the Customs Act, the rate of interest payable on delayed refund continues to vary with successive notifications issued by the Central Government during the period of delay.

Analysis: The expression "for the time being fixed by the Central Government" was held to govern each point of continuing delay after the expiry of the statutory period. The successive notifications issued under Section 27A were treated as operative for the relevant periods after their respective dates, and not as confined to the first point of default. A construction fixing one uniform rate for the entire period of delay would render the later notifications redundant.

Conclusion: The rate of interest payable under Section 27A changes with the applicable notification during the continuing period of delay, and the uniform rate applied by the appellate authority was not sustainable.

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