Admitted input tax credit refund cannot be withheld on procedural objections; supporting invoices must be verified and the claim processed.

An admitted excess input tax credit refund cannot be withheld indefinitely on procedural objections where the substantive entitlement is not in dispute and the remaining issue is verification of supporting documents. The High Court treated the department's objection about pre-bifurcation audit completion and non-furnishing of purchase invoices as a compliance issue, not a denial of the refund claim on merits. The petitioner was directed to submit original invoices, or copies if originals had already been filed, so that the refund could be processed and paid in accordance with law.

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Issues: Whether the petitioner was entitled to processing and payment of the admitted excess input tax credit refund, notwithstanding the respondents' objection based on pre-bifurcation audit formalities and non-furnishing of purchase invoices.

Analysis: The refund claim was not in dispute on merits, as the departmental proceedings themselves showed excess credit and nil net payable after adjustment. The objection raised was only that, because the credit related to the pre-bifurcation period, refund audit and cross-verification had not yet been completed and the original purchase invoices had not been furnished. In these circumstances, the dispute was treated as one of procedural compliance rather than entitlement. The petitioner was therefore directed to submit the original invoices, if not already filed, or copies if originals had already been submitted, so that the department could process the claim in accordance with law.

Conclusion: The petitioner was held entitled to have the refund claim processed and paid in accordance with law after submission/verification of the purchase invoices.

Ratio Decidendi: An admitted tax refund cannot be withheld indefinitely on technical or procedural grounds where the only remaining requirement is verification of supporting documents.

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