Collected 'Duty' Cannot Be Reclassified as 'Deposit'; Impacts Interest on Delayed Refunds.

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....Interest on delayed refund - scope of 'duty' and 'deposit' - an amount determined as 'duty' by processing the Bill of Entry and collected by the Revenue can never be termed as a “deposit”, even assuming that such collection, later, is found to be either unlawful or excessive - the claim of the Revenue that the amount collected was only a “deposit” and not “duty”, is factually incorrect and thus liable to be rejected.....