Reassessment-Based Export Duty Refund Limitation Starts When Excess Payment Becomes Ascertainable, With Interest Following the Statutory Refund Period

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....Refund of excess export duty following reassessment of steel-slab shipping bills remains subject to statutory refund limitation; an alleged mistake of law cannot invoke general limitation law or Article 265 to bypass it. Where additional duty paid by challan was absent from shipping bills, Let Export Orders and contemporaneous assessment records, and a departmental recomputation constituted reassessment, the excess became ascertainable only on reassessment. A prior refund application read with a pending correction request was therefore within time. Interest on delayed refund runs from the day after three months from reassessment, rather than from the earlier application, because the claim could not be both premature before ascertainment and overdue for interest purposes.....