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    <title>2025 (12) TMI 1142 - CESTAT CHENNAI</title>
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    <description>The dominant issue was whether the refund claim was barred by limitation under s.11B of the Central Excise Act despite being asserted as an amount paid under Rule 6(3)(i) of CCR, 2004 relating to exempted goods. Applying SC in Mafatlal, the Tribunal held that all refunds of amounts collected as excise duty must be claimed only under s.11B/Rule 11, and the &quot;mistake of law&quot; theory based on a later SC decision cannot extend limitation. Since the dispute period was April 2011-March 2014 and the appellate authority had already allowed refund only for the non-time-barred portion (accepted by the department), the balance was time-barred; the appeal was dismissed.</description>
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    <pubDate>Wed, 17 Dec 2025 00:00:00 +0530</pubDate>
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      <title>2025 (12) TMI 1142 - CESTAT CHENNAI</title>
      <link>https://www.taxtmi.com/caselaws?id=783602</link>
      <description>The dominant issue was whether the refund claim was barred by limitation under s.11B of the Central Excise Act despite being asserted as an amount paid under Rule 6(3)(i) of CCR, 2004 relating to exempted goods. Applying SC in Mafatlal, the Tribunal held that all refunds of amounts collected as excise duty must be claimed only under s.11B/Rule 11, and the &quot;mistake of law&quot; theory based on a later SC decision cannot extend limitation. Since the dispute period was April 2011-March 2014 and the appellate authority had already allowed refund only for the non-time-barred portion (accepted by the department), the balance was time-barred; the appeal was dismissed.</description>
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      <pubDate>Wed, 17 Dec 2025 00:00:00 +0530</pubDate>
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