Statutory limitation controls refund claims before departmental authorities; general limitation law cannot extend the prescribed time limit.

A refund claim for tax paid twice was held to be governed strictly by the limitation period prescribed in the parent enactment and the relevant rules. The Tribunal applied the settled principle that a claim made before a departmental authority cannot invoke the general law of limitation to extend or bypass the statutory time limit. As the refund application was filed beyond the prescribed period, it was barred by limitation and the rejection of the claim was upheld.

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Issues: Whether a refund claim for tax paid twice was barred by limitation prescribed under the governing rules, and whether the general law of limitation could be invoked for a claim made before the departmental authority.

Analysis: The claim for refund was made beyond the period prescribed in the relevant rules. The Tribunal applied the settled principle that refund claims before departmental authorities must be made strictly within the statutory framework, and that the limitation prescribed by the parent enactment and the rules framed under it cannot be bypassed by resort to the general law of limitation. The earlier controversy on the point stood resolved by the Supreme Court, and the subsequent precedent followed the same view.

Conclusion: The refund claim was barred by limitation and the dismissal of the claim was upheld.

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