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1992 (4) TMI 142 - CEGAT, MADRASExtract: .......n for raising the demand. The demand can be raised only with reference to the date on which the refund is made. In file present case, as mentioned above, appropriation of the amount can be the date of the refund and, therefore, the limitation has to necessarily run from that date. In view of the above I hold that the demand is barred by limitation.
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