Refund of excise duty and interest on delayed refunds; interest limited to 6% under statutory refund rules, 12% disallowed

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....Refund claims under the excise refund regime are governed by the statutory refund provision, and interest on delayed refunds follows the statutory interest rule; therefore interest is payable at the notified 6% rate and a claim for 12% was rejected. A carved-out rule treats deposits made as pre-deposit for filing appeals differently: interest on such deposits begins from the deposit date under the provision governing pre-deposit interest, not the general refund interest date. The tribunal upheld the Commissioner's order on duty, denied remission for semifinished goods, and dismissed the appeal on these grounds.....