JUDGMENT :

SONIA GOKANI, J.

1. This is a petition preferred under Articles 226 and 227 of the Constitution of India arising out of the order No.18-20/2019/CX(WZ)ASRA/Mumbai dated 30.08.2019 passed by the Principal Commissioner and Ex-Officio Additional Secretary to the Government of India, denying the petitioner the rebate claim on the ground of limitation.

2. The facts shorn of the details are as follows:

2.1. The petitioner is engaged in manufacture and export of polyester chips and polyester yarn. An export order was received by the petitioner from M/s. Flex Middle-Easter FZE, Dubai for export of 160480 kgs of polyester chips Textile Grade-160 MTS (hereinafter to be referred to as "the goods") The petitioner manufactured the said goods from the factory located at village: Jolwa; Taluka Palsana, District: Surat and cleared the same with payment of Central Excise Duty. The petitioner cleared the said goods under the prescribed FORM ARE-1 along with all requisite documents and filed the shipping bills bearing No.8696246 dated 27.07.2010 by declaring the value of the said goods of Rs.81,09,800/- from the port of Nav Sheva, JNPT at Raigadh.

2.2. The rebate of central excise duty paid on e