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Duplicate customs duty payments compelled by a payment-portal error after the original duty liability is discharged constitute unauthorised excess collection, not customs duty. Accordingly, the statutory limitation for customs-duty refund claims does not govern recovery of the duplicate payment. A precedent involving valid tax payment followed by exemption is inapplicable. Setting aside the refund rejection permits the refund, while the connected recovery demand for an already sanctioned refund becomes infructuous.
Duplicate customs duty payments compelled by a payment-portal error after the original duty liability is discharged constitute unauthorised excess collection, not customs duty. Accordingly, the statutory limitation for customs-duty refund claims does not govern recovery of the duplicate payment. A precedent involving valid tax payment followed by exemption is inapplicable. Setting aside the refund rejection permits the refund, while the connected recovery demand for an already sanctioned refund becomes infructuous.
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