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of HC held that Extra Duty Deposit (EDD) does not constitute customs duty under Section 27 of Customs Act, 1962, but rather functions as a security deposit as clarified in Circular No.5/2016-Customs. EDD was collected to secure potential customs duty liability due to alleged under-declaration concerns. The limitation period prescribed under Section 27 for customs duty refund claims is not applicable to EDD refunds. The court rejected respondent's stance that refund application was time-barred, noting that EDD remained distinct from duty determined by Special Valuation Branch. The impugned order's reliance on limitation period was found legally untenable, leading to petition's allowance.
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