Finality of duty determination bars refund claims used to reopen earlier computation disputes.

A refund claim cannot be used to reopen a duty demand that has already been confirmed in adjudication, upheld on appeal, and paid under the competent authority's order. Where the assessee contends that the differential duty was wrongly computed, the proper remedy is to challenge that computation in the original proceedings, not through refund proceedings. A concluded determination cannot be indirectly assailed by questioning the earlier calculation in a later refund claim, so the refund claim was held not maintainable.

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Issues: Whether the assessee could seek refund of differential duty by contending in refund proceedings that the amount had been wrongly worked out in the earlier adjudication and appellate proceedings.

Analysis: The differential duty had already been demanded, confirmed, upheld in appeal, and paid pursuant to the competent authority's order. A refund claim could not be used to reopen or question that concluded determination on the ground that the duty was incorrectly computed. The proper course was to challenge the computation in the original adjudication or appeal, not by way of refund proceedings. The principle applied was that an order which has attained finality cannot be indirectly assailed through a refund claim.

Conclusion: The refund claim was not maintainable, and the appeal failed.

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