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Issues: Whether the refund claim was barred by limitation and could be maintained on the basis of decisions rendered in other cases.
Analysis: Section 11B governs refund claims under the excise regime and prescribes the limitation period for seeking refund. A statutory time-limit cannot be ignored merely because another assessee has obtained relief in a different matter. The governing principle is that a claimant must pursue the refund within the statutory framework applicable to its own case; a decision in another case does not reopen a finalised claim or extend limitation. The rule against unjust enrichment also underlies the refund regime, and refund is not available unless the burden of duty has not been passed on.
Conclusion: The refund claim was not maintainable beyond the statutory limitation, and reliance on refunds granted in other matters was rejected. The issue was decided against the assessee and in favour of the Revenue.
Final Conclusion: The appeal failed because the refund demand could not be sustained outside the statutory refund provisions and limitation period.
Ratio Decidendi: A refund of excise duty must be claimed strictly in accordance with the statutory refund provision and within the prescribed limitation, and a claimant cannot reopen a finalised claim or seek refund merely on the strength of a decision in another person's case.