Packing materials, labels, cartons and plastic containers used...

Packing materials, labels, cartons and plastic containers used to market packaged tea qualify as inputs used in the course or furtherance of business and may generate refundable accumulated input tax credit under the inverted duty structure. The refund analysis does not distinguish between principal and ancillary inputs, and identical GST rates on bulk and packaged tea do not exclude credit arising from higher-taxed packing materials. The rate-reduction circular concerning accumulation caused by GST-rate changes on the same goods does not apply where accumulation arises from packing materials, and it cannot restrict a refund otherwise available under the statute. The refund sanction was sustained and the Revenue appeal was dismissed.