Accumulated input tax credit refunds under an inverted duty...

Accumulated input tax credit refunds under an inverted duty structure depend on the tax rates applicable to supplies, not on whether the registered person is a manufacturer or trader. A circular addressing accumulation caused by a GST rate reduction on the same goods does not exclude refunds for finished apparel supplied at an unchanged rate; higher-taxed inputs may remain eligible under the prescribed formula. Refunds must be computed tax-period-wise, and period-specific calculation satisfies that requirement. Verification must address ineligible credit, invoice reconciliation and credit relating to zero-rated supplies; unsupported objections do not displace findings based on examined records. The refund claims were sustained and the Revenue appeals dismissed.