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2019 (3) TMI 1722 - AT - CustomsRefund of SAD - refund was denied on the ground of limitation following the decision in the case of Sony India Pvt. Ltd. v. CC, New Delhi [ 2014 (4) TMI 870 - DELHI HIGH COURT ] - HELD THAT:-It is matter of legal jurisprudential limitation cannot start forum before a right to claim refund arises or crystallizes - Hon’ble Delhi High Court in Sony India Pvt. Ltd. have also laid down that prior to the date of sale and payment of VAT, limitation cannot start to run, even if provided wrongly by Notification No. 93/2008-Cus. Refund allowed - appeal dismissed - decided against Revenue.
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