Quarterly refund filing rule is procedural only; breach does not defeat substantive export credit refund entitlement.

A notification requiring refund claims to be filed not more than once in a quarter was treated as an orderly verification requirement, not a condition that extinguished the substantive refund right under the input credit scheme. Filing two claims for different export periods in the same quarter was therefore a procedural breach that did not defeat refund entitlement where export, credit accumulation, and timeliness were otherwise undisputed. The admissible refund remained payable, but the same amount could not be claimed twice.

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Issues: Whether the condition in clause 2 of Appendix to Notification No. 85/87-C.E. requiring refund claims to be submitted not more than once in any quarter in a calendar year barred refund where claims for different export periods were filed in the same quarter, and whether such non-compliance defeated the substantive refund entitlement under Rule 57F(4).

Analysis: The refund claims were rejected solely because two claims relating to different periods were filed in the same quarter. The filing requirement in the notification was treated as a mechanism for orderly verification, but the underlying right to refund arose from the substantive scheme governing credit on inputs used in exported goods. The Court held that the expression in the notification meant that only one claim could be filed in a particular quarter, yet the breach of that requirement did not destroy the refund entitlement where export and accumulation of credit were not in dispute and the claims were otherwise within time. The defect was therefore procedural and could not override the substantive benefit. The claim for the same amount could not be granted twice.

Conclusion: The filing of more than one refund claim in the same quarter did not bar refund on merits, and the assessee was entitled to refund of the admissible amount, but not to double refund of the same sum.

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