Custom, Excise & Service Tax Tribunal
M/S T T Limited vs Meerut-I on 20 February, 2026
CUSTOMS, EXCISE & SERVICE TAX APPELLATE TRIBUNAL
ALLAHABAD
REGIONAL BENCH - COURT NO.I
Excise Appeal No.70574 of 2025
(Arising out of Order-in-Appeal No.MRT-EXCUS-000-APPL-MRT-266-2024-25,
dated-18.02.2025 passed by Commissioner (Appeals), CGST & Central Excise,
Noida)
M/S T T LIMITED .....Appellant
(109-110 Km Stone, NH No. 24, Delhi
Moradabad, Amroha, Uttar Pradesh 244235)
VERSUS
Commissioner, Central Goods & Service Tax, Meerut
....Respondent
(Mangal Pandey Nagar, Opp. Ch. Charan Singh University, Meerut-250 005) APPEARANCE:
Shri Nishant Mishra, Advocate & Shri Bimal Jain, Advocate for the Appellant Shri A. K. Choudhary, Authorized Representative for the Respondent CORAM: HON'BLE MR. P.K. CHOUDHARY, MEMBER (JUDICIAL) FINAL ORDER NO.-70045/2026 DATE OF HEARING : 10.11.2025 DATE OF DECISION : 20.02.2026 P. K. CHOUDHARY:
Appeal No. 70574/2025 arises from Order-in-Appeal No. MRT/EXCUS/000/APPL-MRT/266/2024-25 dated 18.02.2025, whereby the Appellate Authority has upheld the Order-in- Original No. 05/Refund/DC/Bij/24-25 dated 10.10.2024 passed by the Adjudicating Authority.
2. Brief facts of the case are such that the Appellant was holding status of 100% EOU (Export Oriented Unit), registered under No. AAACT0767AXM002 and was engaged in the manufacturing of cotton yarn falling under Chapter 52 of the 2 Excise Appeal No.70574 of 2025 Central Excise Tariff Act, 1985. The Superintendent of Customs & Central Excise, Range-1, Gajraula ("Superintendent- Gajraula"), issued a letter C. No. 13-Mize/R-I- Gaj/GSM/2000.2001/426 dated 01.12.2000 demanding payment of Additional Duty of Excise ("AED (T&T)") on yarn cleared to the Domestic Tariff Area ("DTA") w.e.f. 01.03.2000, as per Section 3(1) of the Central Excise Act, 1944 ("Central Excise Act") and Notification No. 08/97 dated 01.03.1997, as amended by Notification No. 11/2000 dated 01.03.2000. The Appellant replied via letter dated 16.06.2001 stating that duty is not payable, hence, such payment was not required to be made in terms of Notification No. 55/91 dated 25.07.1991 and as was decided vide the Adjudication Order OIO No. 49/2001 dated 23.04.2001.
3. However, the Superintendent-Gajraula served another letter bearing C. No. I-CL-PL/R-I GAJ/2000-2001/695 dated 12.10.2001 stating that the Appellant is liable to pay duty along with interest @24% as per Circular No. 554/50/2000-CX dated 19.10.2000. The Appellant reiterated that the duty on DTA sale is exempt under Notification No. 55/91 dated 25.07.1991. It is the case of Appellant that on account of directions of the Superintendent-Gajraula, the Appellant paid the duty amounting to Rs 22,30,445/- through Form TR-6 (32 challans) dated 30.12.2000 to 29.03.2003 under-protest on 22.10.2001 and explicitly communicated through a letter dated 22.08.2001 that the duty was not payable in light of Notification No. 55/91-CE dated 25.07.1991.
4. The Appellant thereafter filed refund claim of the said payment of Rs 22,30,445/- made under-protest on 27.06.2022, as the Appellant's unit was debonded for conversion into the EPCG (Export Promotion Capital Goods) Scheme on 15.11.2007, because of which Appellant could not file refund claim of the said paid duty within the stipulated time due to major shuffling of exclusively commercial staff from Gajraula unit on account of 3 Excise Appeal No.70574 of 2025 closure of unit, as the old records were also shifted from Gajraula unit and therefore the Appellant had to reconstitute the file containing the relevant documents.
5. The refund claim was sent to the Superintendent-Gajraula for verification vide letter dated 29.06.2022, which was denied by the Superintendent-Gajraula vide letter C. No. 20- CGST/Misc/T T L/RFD/GJL/09/2021/146 dated 17.08.2022. The Assistant Commissioner of CGST, Division-Bijnor ("Adjudicating Authority"), issued the Show Cause Notice1 bearing C. No. V(30)Div-Bij/TT Limited/refund/126/2022/752 dated 07.09.2022, calling upon the Appellant to submit explanation as to why the refund claim should not be rejected. The Appellant reiterated its stance that the duty was not applicable on cotton yarn sold in the DTA by a 100% EOU as per Notification No. 55/91-CE dated 25.07.1991 and that they had paid the duty under protest, hence the time limit for filing the refund claim under Section 11B of the Central Excise Act, which governs "Claims for Refund of Duty," does not apply in the Appellant's case.
6. The Adjudicating Authority passed Order-in-Original No. 01/Refund/AC/BIJ/2022-23 dated 15.12.2022 ("OIO-1"), without providing an opportunity of hearing to the Appellant and concluded that the refund claim filed by the Appellant was barred by limitation of time since the refund claim was filed beyond one year from the date of de-bonding, i.e., from 15.11.2007, under Section 11B of the Central Excise Act.
7. Aggrieved with OIO-1, the Appellant filed an appeal before the Commissioner, Central GST (Appeals), Meerut ("Appellate Authority"). The Appellate Authority, through the Order-in- Appeal No.NOI-EXCUS-002-APP-14-24-25 dated 22.04.2024 ("OIA-1"), found that the Appellant was entitled to refund of AED (T&T) paid by them, because the second proviso to Section 1 SCN 4 Excise Appeal No.70574 of 2025 11B(1) of the Central Excise Act provides that the limitation for filing a refund application is not applicable where duty is paid under protest. The Appellate Authority held that any payment made pursuant to a demand by the department which is not voluntary can be treated as a payment under-protest. The Appellate Authority further noted that the record confirms that the Appellant paid AED (T&T) under protest after it was pointed out by the Department, and duly informed the Department. There is no document or order on record indicating that the protest was ever withdrawn or vacated. The Adjudicating Authority's view that the protest ended upon de-bonding of the EOU in 2007 is incorrect, as no communication or order to that effect exists. Therefore, the payment remained "under protest"
at the time of filing the refund claim, and the limitation period does not apply. Accordingly, the OIO-1 was set aside and the appeal was allowed and the Department was directed to process the refund with interest within 30 days from receipt of the OIA-
1.
8. Thereafter, the Superintendent, Central GST, Range- Dhampur ("Superintendent Dhampur") submitted his verification report and submitted that the refund to the Appellant is admissible. Whereas, when the said refund claim was sent to the pre-audit branch of the CGST Commissionerate, Meerut, in terms of Circular No. 869/07/2008-CX dated 16.05.2008 for audit clearance, the competent authority found the refund amount of Rs 22,30,445/- to be admissible for refund, however, in the case of interest on the said amount, the competent authority mentioned that the interest was to be calculated from 27.09.2022, i.e. the day after three months from the date of filing of refund application, @ 6% per annum till the date of disbursement of the refund amount of Rs 22,30,445/-. The Appellant, then, submitted letters to the Department on 29.05.2024, 05.08.2024, and 02.09.2024, requesting compliance with the OIA-1. However, no response was received from the Department.
5 Excise Appeal No.70574 of 20259. The Adjudicating Authority, as per the findings of the pre- audit branch of the CGST Commissionerate, Meerut; sanctioned the refund claim of Rs 22,30,445/- vide the Order-in-Original No. 05/Refund/DC/Bij/24-25 dated 10.10.2024, communicated through digital mode on 24.10.2024 ("OIO-2"), under 11B of the Central Excise Act read with Section 142(3) of the CGST Act, 2017 and interest amount of Rs 2,72,786/- on the said refund claim under section 11BB of the Central Excise Act.
10. Aggrieved with OIO-2, the Appellant filed appeal before the Appellate Authority contending that the Appellant is entitled to interest @12% per annum against the refunded amount instead of 6% per annum from the date of actual payment and not from the date after the lapse of three months of filing the refund claim, as provided by the Adjudicating Authority in OIO-
2.
11. The Appellate Authority thereafter passed the Impugned OIA rejecting the appeal and upholding the OIO-2 by concluding that interest becomes payable after the expiry of three months from the receipt of application for grant of refund under Section 11B(1) of the Central Excise Act. Thus, it has been held that since the Appellant filed application of refund on 27.06.2022, hence interest would be payable after the lapse of three months from the date of claiming refund, i.e., from 27.09.2022 and also that interest under Section 11BB would be limited for the period of delay caused, i.e. from the date of filing of the refund application. The Appellate Authority has also held that Notification No. 67/2003-C.E. (N.T.) dated 12.09.2003 under Section 11BB of the Central Excise Act has fixed the rate of interest on delayed refund as 6% per annum, hence the rate of 12% per annum sought by the Appellant is fallacious and contrary to law.
12. Aggrieved by the Impugned Order, the Appellant has filed the present appeal.
6 Excise Appeal No.70574 of 202513. Ld. counsel for the Appellant submits that the duty paid under-protest and prior to any adjudication cannot be construed as 'duty' payable under the Central Excise Act. He further submits that unless such an amount is appropriated against a confirmed demand through a proper adjudication order, it cannot acquire the character of duty and remains merely a deposit, retained without the authority of law. He also emphasized that the department has itself acknowledged that the levy was unsustainable and, accordingly, a refund was also sanctioned. Therefore, once it is admitted that no duty was legally payable, the amount deposited under-protest cannot be treated as 'duty' for the purposes of invoking section 11BB of the Central Excise Act. To buttress his submissions, he relied on the of judgment of Hon'ble Meghalaya High Court in The Principal Commissioner of Central Goods and Service Tax vs. M/s. Green Valley Industries Pvt. Ltd. [MC (Central Excise Ap.) No. 1/2023 in Central Excise Ap.No.4/2023 dated 26.07.2023], wherein it has been held that a deposit made at a time when no quantified claim was made could not be equated with duty under Section 11B of the Central Excise Act and such a deposit did not attract the statutory limitation or the interest condition under Section 11BB of the Central Excise Act, being outside the purview of "duty". He also relied upon the order passed by the Tribunal in M/s Parle Agro Pvt. Ltd. vs. Commissioner, Central Goods & Service Tax, Noida (Vice-Versa), 2022 (380) E.L.T. 219 (Tri. - All.).
14. Learned Departmental Authorized Representative for the Revenue reiterated the findings recorded in the impugned order and submitted that interest has been rightly denied to the Appellant and accordingly, the appeal filed by the Appellant being devoid of any merits may be dismissed.
15. Heard both the sides and perused the appeal records.
7 Excise Appeal No.70574 of 202516. I find that the following issues arises for determination in the present appeal:
(i) Whether the interest is payable from the date of deposit of the duty, or from the date of expiry of three months after the date of filing the refund application?
(ii) Whether the Appellant is entitled to interest at the rate of 12% per annum instead of the 6% per annum?
17. Before discussing the aforesaid issues, it would be apposite to first take note of the judgment rendered by the jurisdictional High Court of Allahabad in Principal Commissioner Central Goods and Service Tax vs. M/s Parle Agro Private Limited [Central Excise Appeal No. 18 of 2021 dated November 14, 2025], wherein an appeal was filed by the Department against this Tribunal's order in M/s Parle Agro Pvt. Ltd. vs. Commissioner, Central Goods & Service Tax, Noida (Vice- Versa), 2022 (380) E.L.T. 219 (Tri. - All.), which decision has also been relied upon by the Appellant herein. It is significant to observe that the Hon'ble High Court has unequivocally affirmed the view taken by this Tribunal and, in the process, has conclusively settled the very issues which arise for consideration in the present proceedings.
18. In Parle Agro (Tri. - All.) (supra), this Tribunal held that Section 11B will not be applicable in cases where the assessee has not demanded the refund of duty, such as the revenue deposit in that case. There is no provision in the Central Excise Act, which deals with refund of revenue deposit and so rate of interest has not been prescribed, when revenue deposit is required to be refunded. I reproduce below the relevant portion of the judgment for reference:
"25. Before adverting to the aforesaid decisions relied upon by the learned counsel for the Appellant, it would 8 Excise Appeal No.70574 of 2025 be appropriate to refer to the provisions contained in the Central Excise Act 1944 [Excise Act] relating to refund.
28. Section 11B of the Excise Act deals with claim for refund of duty and interest, if any, paid on such duty. It provides that any person claiming refund of any duty of excise and interest may make an application for such refund of duty and interest.
29. Section 11BB provides for interest on delayed refund. It states that if any duty ordered to be refunded under sub-section (2) of section 11B is not refunded within three months from the date of receipt of the application, than the applicant shall be entitled to interest after the expiry of three months from the date of receipt of the application at such rate not below 5% and not exceeding 30% as may be notified by the Central Government in the Official Gazette.
30. In the present case, the provisions of section 11B of the Excise Act would not be applicable. This is for the reason that the Appellant was not claiming refund of duty. The applicant, as noticed above, had claimed refund of the revenue deposit. Such a finding has also been clearly recorded by the Tribunal in the order dated 31.01.2017, which order has attained finality.
33. There is no provision in the Excise Act, which deals with refund of revenue deposit and so rate of interest has not been prescribed, when revenue deposit is required to be refunded."
19. This Tribunal in Parle Agro (Tri. - All.) (supra) further held that in case of refund of revenue deposit when the rate of interest has not been prescribed, as a matter of general practice, 9 Excise Appeal No.70574 of 2025 interest at the rate of 12% per annum is awarded on the revenue deposit. The relevant para is quoted for the sake of reference:
"39. In this connection reference can also made to the decisions of the Allahabad High Court in Pace Marketing Specialities and Ebiz. Com Private Limited, wherein after making reference to the decision of the Supreme Court in Sandvik Asia Ltd., the High Court granted interest at the rate of 12% per annum in matters relating to refund of amount deposited during investigation and adjudication.
40. In Riba Textiles, the Tribunal also granted interest at the rate of 12% on refund of amount deposited during investigation and at the time of entertaining the stay application.
41. In view for the aforesaid decisions, and the fact that the rate of interest varies from 6% to 18% in the aforesaid Notifications issued under sections 11AA, 11BB, 11DD and 11AB of the Excise Act, the grant of interest @12% per annum seems to be appropriate.
42. Thus, for the reason stated above, Excise Appeal No. 70628 of 2019 is allowed and the order dated 28.05.2019, passed by the Commissioner (Appeals) is modified to the extent that interest shall be granted to the Appellant @12% instead of @6% from the date of deposit till the date of payment. Excise Appeal No. 70674 of 2019 filed by the Principal Commissioner for setting aside the order dated 28.05.2019, passed by the Commissioner (Appeals) is dismissed."
20. While affirming the aforesaid findings of this Tribunal, the Hon'ble High Court, in Principal Commissioner, Central Goods and Service Tax v. M/s Parle Agro Private Limited (supra), has held as under:
10 Excise Appeal No.70574 of 2025"20. Seen in that light, the interest liability incurred by the revenue does not flows in terms of the order dated 30.10.2018 passed by the Assistant Commissioner. It is not traceable to Section 11BB of the Act. For the reasons noted above that liability has been incurred by virtue of revenue receipt of the assessee deposited under force or in circumstances other than those governing payment of duty, fines and penalties. To that extent the finding of the Tribunal giving rise to this appeal cannot be faulted.
21. The decision of Hon'ble Supreme Court in the case of Ranbaxy (supra) is not in favour of the revenue. In fact is not on the point. There after making deposits of amounts towards payment of duty, the assessee had claimed rebate. The entitlement to rebate inheres in it the liability to pay duty. In other words the claim for rebate may arise only where there pre-exists a liability to pay duty. That liability not only existed that had been discharged by Ranbaxy. Later, the claim for refund had been made.
22. Similarly in Hamdard (supra) after payment of duty the claim for refund had been made, which was allowed. As in the case of rebate so in refund, claim arose as a result of classification dispute. The duty liability pre- existed.
23. In the present case duty liability has not been shown to pre-exist as may warrant any further consideration. Suffice to note the decisions in Ranbaxy (supra) and Hamdard (supra) are wholly distinguishable to the facts of present case.
24. In view of the above discussion question no.1 is answered in the affirmative i.e. against the revenue and in favour of the assessee.
11 Excise Appeal No.70574 of 202525. Insofar as question no.2 is concerned, in the instant case the Tribunal has discussed all relevant notifications and, thereafter, reached the conclusion that the interest rate has varied from 6% to 18%. Considering the long duration of retention of the revenue receipt of the assessee, it has awarded 12%. We do not find any substantial question of law has arisen with respect to payment of rate of interest. Suffice to note that the amount was forcibly extracted from the assessee in the year 1994 and it came to be refunded in the year 2018 after 24 years.
26. In view of such facts and law the question no.2 is answered accordingly. 27. Consequently, the appeal is dismissed. No order as to costs."
From the above pronouncement of the Hon'ble High Court, it is manifest that the view taken by this Tribunal in Parle Agro (supra) has received unequivocal approval. The Hon'ble High Court has categorically upheld the finding that the provisions of section 11B of the Central Excise Act are not applicable to cases involving refund of revenue deposit, and that, in the absence of any specific statutory provision governing such refunds, the grant of interest at the rate of 12% per annum is justified and legally sustainable.
21. Having taken note of the binding judgment of the Hon'ble High Court of Judicature at Allahabad, in Principal Commissioner, Central Goods and Service Tax v. M/s Parle Agro Private Limited (supra), which conclusively settles the legal position, the issues arising in the present appeal are now examined one after the other in the light of the said decision, as well as the additional grounds urged by the parties.
12 Excise Appeal No.70574 of 202522. With respect to the first issue, concerning the commencement point for calculation of interest, the Appellant has contended that interest is payable from the date of deposit of the amount, whereas the Revenue has argued that interest, if any, can be granted only after the expiry of three months from the date of filing of the refund application, by placing reliance on section 11BB of the Central Excise Act. So, first, it is important to understand the applicability of Section 11BB of Act in this case. I reproduce below the relevant portion of Section 11BB, for the sake of reference:
"11-BB. Interest on delayed refunds.-- If any duty ordered to be refunded under sub-section (2) of Section 11-B to any applicant is not refunded within three months from the date of receipt of application under sub- section (1) of that section, there shall be paid to that applicant interest at such rate, [not below five per cent and not exceeding thirty per cent per annum as is for the time being fixed 3[by the Central Government, by notification in the Official Gazette,]] on such duty from the date immediately after the expiry of three months from the date of receipt of such application till the date of refund of such duty:
Provided that where any duty ordered to be refunded under sub-section (2) of Section 11-B in respect of an application under sub-section (1) of that section made before the date on which the Finance Bill, 1995 receives the assent of the President, is not refunded within three months from such date, there shall be paid to the applicant interest under this section from the date immediately after three months from such date, till the date of refund of such duty."
After due perusal of Section 11BB of the Central Excise Act, it is very clear that the interest on delayed refunds of duty paid under Section 11B, the Central Excise Act will be 13 Excise Appeal No.70574 of 2025 applicable through this provision, only when the matter of concern is "refund of duty". The applicability of Section 11BB of the Central Excise Act, therefore, hinges upon the determination as to whether the amount refunded in the present case is in the nature of "duty" under Section 11B of the Central Excise Act or merely a "deposit".
23. On this aspect, the Appellant has consistently maintained that the amount was paid under protest, during the course of investigation, and prior to any adjudication or confirmation of demand. It has been emphasized that unless such an amount is appropriated towards a confirmed demand through a valid adjudication order, it does not acquire the character of duty and continues to remain a deposit, retained without the authority of law.
24. I find considerable force in the aforesaid submission. It is an admitted position that at the time of deposit of the amount, there was neither any quantified demand nor any adjudication determining duty liability. The Revenue itself has subsequently acknowledged that the levy was unsustainable and has sanctioned refund of the entire amount. Once it is accepted that no duty was legally payable, the amount deposited under protest cannot be treated as "duty" so as to attract the provisions of sections 11B and 11BB of the Central Excise Act.
25. This legal position finds authoritative support from the judgment of the Hon'ble Meghalaya High Court in M/s Green Valley Industries Pvt. Ltd. (supra) cited by the Appellant, wherein it has been categorically held that a deposit made at a stage when no quantified demand exists cannot be equated with duty under Section 11B, and consequently, the limitation and interest provisions under section 11BB are not applicable to such deposits. A similar view has been taken by the Tribunal in M/s Churchit International vs. Commissioner of Customs (Exports), New Delhi [Customs Appeal No. 51301 of 2023 14 Excise Appeal No.70574 of 2025 dated 06.09.2024, wherein it has been held that amounts deposited during investigation or adjudication proceedings are in the nature of deposits under protest and interest thereon is payable from the date of deposit till the date of refund.
26. The issue is no longer res integra in view of the decision of this Tribunal in Parle Agro (supra), which has been affirmed by the Hon'ble Allahabad High Court. It has been conclusively held therein that Section 11B/11BB of the Central Excise Act applies only to refunds of duty and has no application to refunds of revenue deposits. Consequently, the restriction contained in Section 11BB regarding commencement of interest after expiry of three months from the date of filing of the refund application cannot be imported into cases involving refund of revenue deposits. Therefore, the Appellate Authority, while passing the Impugned OIA, has failed to examine the applicability of Section 11BB of the Central Excise Act in the correct legal perspective and has mechanically denied interest from the date of deposit by treating the amount as duty, without recording any finding as to how the amount acquired the character of duty.
Accordingly, Issue No. (i) is answered in favour of the Appellant.
27. Now the second issue for consideration relates to the appropriate rate of interest payable on the refunded amount. The Appellant has contended that, since the amount refunded is in the nature of a deposit made under protest and not duty paid under the Central Excise Act, interest at the rate of 12% per annum is payable, in accordance with settled judicial practice in M/s. Sunrise Immigration Consultants Private Limited vs. CG& ST-Chandigarh [Service Tax Appeal No. 60347 of 2022 dated 11.04.2023]among other judgments wherein it has been held that any amount that is deposited during the pendency of the adjudication proceedings or investigation is in the nature of deposit made under protest, and so, the assessee is entitled to claim interest from the date of payment of the initial amount till the date of its refund at the rate of 12% where the refund is delayed. The Revenue, however, has sought to sustain the grant 15 Excise Appeal No.70574 of 2025 of interest at the rate of 6% per annum, by placing reliance on the rates prescribed under Section 11BB of the Central Excise Act.
28. As already discussed, while dealing with Issue No. (i), it stands established that the amount deposited by the Appellant was not duty of excise, but a deposit made under protest during the course of investigation and prior to any adjudication or confirmation of demand. Once it is held that the refunded amount does not partake the character of "duty", the statutory provisions governing refund of duty, including Sections 11B and 11BB of the Central Excise Act, cease to have any application.
29. It is also undisputed that the Central Excise Act does not contain any specific provision prescribing the rate of interest payable on refund of revenue deposits. In such circumstances, the rate of interest has been consistently determined by judicial precedents, based on principles of equity, fairness and reasonableness.
30. This issue is squarely covered by the decision of this Tribunal in M/s Parle Agro (supra), wherein, after examining the statutory scheme and the absence of any prescribed rate of interest for refund of revenue deposits, this Tribunal held that interest at the rate of 12% per annum is appropriate. The aforesaid decision of this Tribunal has been expressly affirmed by the Hon'ble Allahabad High Court in Principal Commissioner, Central Goods and Service Tax v. M/s Parle Agro Private Limited (supra). The Hon'ble High Court has approved the grant of interest at the rate of 12% per annum in cases involving refund of revenue deposits, thereby lending authoritative approval to the said rate.
31. I also find support for this view from the judgments relied upon by the Appellant, wherein interest at the rate of 12% per annum has been granted on refund of amounts deposited during investigation or adjudication, on the ground that such amounts were not legally payable as duty or tax. Therefore, the reliance of 16 Excise Appeal No.70574 of 2025 the Revenue on the provisions of Section 11BB of the Central Excise Act and the corresponding Notification No. 67/2003-C.E. (N.T.) dated 12.09.2003, which prescribe a rate of interest at 6% per annum on delayed refunds of duty, are wholly inapplicable in the Appellant's case, since the amount retained was never legally due as duty and was wrongfully withheld without authority of law.
32. I also note that the amount collected was without any statutory backing or lawful authority is against Article 265 of the Constitution of India. Hence, the denial of rightful interest on such a refund will unjustly enrich the state at the expense of the citizen and constitute a clear violation of the constitutional rights. Accordingly, Issue No. (ii) is answered in favour of the Appellant, holding that interest of INR 59,37,701/- on the refunded amount is payable to the Appellant at the rate of 12% per annum from the date of deposit till the date of actual refund. Since the Impugned OIA has already sanctioned interest amounting to INR 2,72,786/-, the Revenue is directed to sanction and disburse the balance interest of INR 56,64,915/- to the Appellant, in accordance with law.
33. In view of the above, this appeal is allowed, and the Impugned Order-in-Appeal No.29-CE/APPL-MRT/MRT/2023-24/ dated 08.02.2025, to the extent challenged by the Appellant, is set-aside, with consequential reliefs to the Appellant, as per law.
(Pronounced in open court on 20.02.2026) Sd/-
(P. K. CHOUDHARY) MEMBER (JUDICIAL) Nihal