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Itel Industries Ltd vs Commissioner Of Central ... on 18 February, 2016

24. The duty was thus, collected on what can be described as misconstruction of the correct legal position. Even though the petitioner may accuse the department on such misconstruction, nevertheless, the fact remains that the petitioner is seeking refund of the duty paid. Though, the duty may have been paid under protest, period of limitation prescribed under Rule 13 would apply. Counsel for the petitioner, however, relied on the decision of learned Single Judge of Madras High Court in case of Arignar Anna Sugar Mills vs. CEGAT, Chennai reported in 277 ELT 63 and the decision of Division Bench of Kerala High Court in case of Itel Industries Ltd. vs. Commissioner of Central Excise, Calicut reported in 301 ELT 288. Both these judgements referred to section 11B of the Central Excise Act,1944, and hold that on a duty paid under protest, the limitation under section 11B would not apply. Section 11B of the Central Excise Act, however, contains further proviso which provides that the limitation of one year shall not apply where any duty and interest has been paid under protest. There is no such similar provision under Rule 13 of the Rules.
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