Appellant's Cenvat Credit Payment Not Under Protest, Limitation Grounds Insufficient to Contest Duty Demand.

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....Refund claim - payment under protest or not - payment of duty through reversal of cenvat credit - It is found that the appellant on being pointed out by the audit has agreed and paid the duty amount. Thereafter, after the issue of the show-cause notice they have contested the demand on the ground of limitation, the same cannot be considered as payment under protest. - AT....