Budgetary support refund claims must follow the notified reimbursement formula and cannot be partly rejected without reasons.

An eligible industrial unit under the budgetary support scheme was entitled to reimbursement only in accordance with the notified formula, namely 58% of Central tax and 29% of Integrated tax paid through the cash ledger after input tax credit utilisation. The petitioner's eligibility was not disputed, and the respondents had already sanctioned most of the refund. The High Court held that the remaining partial rejection was unsustainable because the impugned orders gave no calculation basis or reasoned justification and were contrary to the scheme's plain terms. The petitioner was therefore entitled to the full refundable amount claimed under the scheme.

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Issues: Whether the petitioner, an eligible industrial unit under the budgetary support scheme, was entitled to full refund of the CGST and IGST paid for the relevant quarters and whether the partial rejection of its refund claim was sustainable.

Analysis: The budgetary support scheme dated 05.10.2017 entitled eligible units to reimbursement of 58% of Central tax paid and 29% of Integrated tax paid through debit in the cash ledger after utilisation of input tax credit. The scheme also preserved the applicability of the earlier exemption conditions and linked admissibility to the tax paid on the prescribed value addition. The petitioner's eligibility was not in dispute and the respondents had sanctioned the major portion of the claim. However, the impugned orders rejected part of the claim without disclosing the calculation basis or any reasoned justification. On the scheme's plain language, the petitioner's claim for the amounts reflected as payable under the prescribed percentages was admissible, and the rejection of the balance was unsupported and contrary to the notification.

Conclusion: The petitioner was entitled to the full refundable amount claimed under the scheme, and the partial rejection of Rs.1,678/- for July 2021 to September 2021 and Rs.7,170/- for January 2022 to March 2022 was unsustainable.

Ratio Decidendi: Where a budgetary support scheme prescribes a fixed formula for reimbursement to eligible units, the authority must determine the refund strictly in accordance with the notified percentage and disclosed methodology, and a reasonless partial rejection contrary to the scheme cannot stand.

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