Refund limitation starts from duty payment by personal ledger account debit, not from RT-12 finalisation, under the applied principle.

For refund limitation, duty paid by debit in the personal ledger account is treated as effective payment, so the limitation period runs from the date of such payment and not from the later finalisation of RT-12 returns. The Tribunal followed the Supreme Court's view on the relevant date for refund claims and applied that principle to hold the claim within limitation. On that basis, the impugned order was set aside and the appeal succeeded.

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Issues: Whether, for the purpose of limitation for refund, the relevant date is the date of payment of duty or the date of finalisation of RT-12 returns.

Analysis: The dispute turned on the point of limitation for filing a refund claim. The Tribunal followed the Supreme Court's view that where duty is paid through debit in the personal ledger account, it constitutes an effective payment, and the relevant date is the date of such payment rather than the later date of finalisation of RT-12 returns.

Conclusion: The relevant date for refund limitation was the date of payment of duty. The impugned order was set aside and the appeal succeeded.

Ratio Decidendi: For refund limitation, duty paid by debit in the personal ledger account is an effective payment, and the limitation runs from the date of such payment.

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