Wrongly sanctioned refund recovery requires Section 11A notice; without it, the demand cannot be sustained.

Recovery of a refund alleged to have been wrongly sanctioned was treated as requiring a demand under Section 11A, and the absence of such notice meant the demand could not stand. The discussion relied on precedent distinguishing the recovery provision from appellate or review provisions, so recovery could not proceed merely on that basis. A later amendment to the refund provision was noted, but it did not affect disposal of the appeal, as any consequence under the amended law would arise separately.

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Issues: Whether a demand for recovery of a refund allegedly wrongly sanctioned had to be made under Section 11A, and whether the absence of such notice rendered the demand time-barred.

Analysis: Recovery of a wrongly sanctioned refund was held to require a demand under Section 11A, and the appellate view that no such notice had been issued was supported by the applicable precedents treating the relevant recovery provision as independent of the appellate or review provisions. The later discussion on the amended refund provision did not alter the disposal of the appeal, as any consequence flowing from subsequent law would arise separately and not in this appeal.

Conclusion: The demand was not sustainable without resort to Section 11A, and the appeal failed.

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