Interest on Delayed CENVAT Credit Refund Starts Three Months After Application per Section 11BB of the Act.

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....Interest on delayed refund of unutilised CENVAT Credit - a fiscal legislation has to be construed strictly and one has to look merely at what is said in the relevant provision; there is nothing to be read in; nothing to be implied; and there is no room for any of intendment. The liability of the revenue to pay interest under Section 11BB of the Act commenced from the date of expiry of three months from the date of receipt of application for refund under Section 11BB(1) of the Act. - HC....