Refund Claim Valid Without Formal Protest; Challenge Considered Sufficient, Limitation Period Not Applicable.

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....Refund claim of amount deposited during investigation - it would not be necessary to lodge the protest as is otherwise provided under the Rules. Since the appellant has challenged the amount which got deposited by him during investigation, the protest is very much lodged on his part not as a party to such decision, the plea of limitation should not debar his claim. - AT....