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Amounts deposited under protest towards disputed central excise liability retained the character of duty and were refundable only under the statutory scheme in Section 11B; payment under protest merely removed the limitation bar and did not convert the sum into an independent revenue deposit carrying interest from the date of deposit. Interest on delayed refund was governed by Section 11BB and accrued only if refund was not made within three months of receipt of the refund application. Accordingly, interest at 6% was payable only after expiry of three months from the application dated 28.04.2025, and the claim for interest from the original deposit dates was rejected.
Amounts deposited under protest towards disputed central excise liability retained the character of duty and were refundable only under the statutory scheme in Section 11B; payment under protest merely removed the limitation bar and did not convert the sum into an independent revenue deposit carrying interest from the date of deposit. Interest on delayed refund was governed by Section 11BB and accrued only if refund was not made within three months of receipt of the refund application. Accordingly, interest at 6% was payable only after expiry of three months from the application dated 28.04.2025, and the claim for interest from the original deposit dates was rejected.
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