Where refund of unutilised input tax credit is rejected because...

Where refund of unutilised input tax credit is rejected because the credit is alleged to be ineligible, the circular permits notice and recovery proceedings under the GST recovery provisions; clause 22 applies only when refund is refused for reasons other than ineligibility, so the objection based on that clause failed. The challenge to the circular was therefore rejected, while the question whether the correct recovery route was one provision or another was left open. Because the statutory second appeal had not been taken on file due to a portal glitch and the required amount had been deposited, the impugned order was kept in abeyance until disposal of the appeal, with liberty to raise all available grounds if the appeal failed.