Amounts paid under protest during provisional assessment were...

Amounts paid under protest during provisional assessment were treated as revenue deposits, not duty, so Section 11B/11BB did not govern the refund or delay interest. Because the payment never acquired the character of duty and no pre-existing quantified liability existed, interest ran from each date of deposit until actual refund, not three months after the refund claim. The Tribunal also held that the proper rate was 12% per annum, with interest already paid to be adjusted.