OthersArticle·20 April 2026
Refund Limitation Trigger
By J the App
Executive Summary
The Tribunal held that payments made during investigation, though initially deposits, assume the character of duty upon appropriation in adjudication.
Consequently, refund claims arising from appellate relief must comply with Section 11B limitation, computed from the date of the first appellate order granting relief, not from subsequent litigation stages.
Delay beyond one year proved fatal.
Issues for Determination
• Whether payments made during investigation are “deposit” or “duty”
• Whether such characterization changes post-ad...
Read the full article in the app
This is a premium article. Download J the App to read the complete content.