JUDGMENT :

M.R. SHAH, J.

1. Feeling aggrieved and dissatisfied with the impugned judgment and order dated 23.07.2021 passed by the High Court of Karnataka at Bengaluru in Writ Appeal No. 249/2020, whereby the Division Bench of the High Court has dismissed the said appeal preferred by the appellant herein and has confirmed the common judgment and order dated 22.11.2019 passed by the learned Single Judge dismissing the writ petitions, upholding the order passed by the respondent rejecting the claim of the appellant for rebate on the ground that the claim was barred by time/limitation prescribed under Section 11B of the Central Excise Act, 1944 (hereinafter referred to as the ‘Act’), the original writ petitioner/appellant herein has preferred the present appeal.

2. The facts leading to the present appeal in nutshell are as under:

That the appellant herein – M/s Sansera Engineering Limited is a manufacturer of excisable goods. It exported goods on payment of excise duty between August, 2015 and October, 2015 and filed claims for rebate of duty paid on the goods exported on 10.02.2017 to the tune of Rs. 29,47,996/-and Rs. 42,27,928/-under Rule 18 of Central Excise Rules, 2002 (hereinafter r