Interest on delayed customs-duty refunds accrues three months after the refund application, notwithstanding intervening appellate litigation.

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....Section 27A of the Customs Act requires interest on delayed customs-duty refunds where the refund is not paid within three months of receipt of the refund application. An appellate order allowing refund is deemed an order under section 27(2), but that deeming provision does not defer the commencement of interest. Where a refund application preceded appellate litigation, statutory interest accrues from expiry of three months after the application until the date of refund payment, despite the refund being granted following the litigation.....