148A. Where a person has sold excisable goods or services and has accounted for and paid excise duty on that sale but has not received any payment from the purchaser, he may, after a period of three years from the date of that sale, or where that person has become legally insolvent, apply to the Commissioner for a refund or remission of the excise duty involved, and, subject to the regulations, the Commissioner may refund or remit the excise duty:

Provided that no application for a refund or remission shall be made under this section after the expiry of five years from the date of sale.