Customs refund interest entitlement: 3 months from application date, not order date.

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....The appellant is entitled to interest on the sanctioned refund from the date after three months from the date of application till the date of sanction of refund. The Commissioner (Appeals) erred in denying interest based on the explanation appended to Section 27A, which is not applicable as the refund sanction order was passed by the Deputy Commissioner of Customs. As per Section 27A, the appellant is eligible for interest after three months from the date of refund application, not from the date of the refund order, in line with the Supreme Court's ruling in Ranbaxy Laboratories Ltd. vs Union of India. The CESTAT set aside the impugned order and allowed the appeal.....