Amounts deposited during investigation at the Department's...

Amounts deposited during investigation at the Department's insistence and while duty liability was still contested were treated as payments made under a mistaken notion of liability, not as voluntary central excise duty. On that basis, the amount did not acquire the character of duty for denying interest under Section 11B. Following its earlier view in Harrisons Industries and distinguishing Goldy Engineering Works, the Tribunal held that interest was payable at 12% per annum on the refunded amount from the date of deposit until the date of refund.