Notification-based restrictions on refunds of unutilized input tax credit for edible oils under an inverted duty structure operate prospectively from 18 July 2022. They do not deny refunds for credit accumulated before that date merely because a fresh application was filed later. A circular cannot retrospectively curtail an accrued input tax credit entitlement without statutory basis. Where a claim concerns the pre-notification period and is filed within the limitation period, rejection based solely on the later filing date is unsustainable. Refund claims require fresh consideration under applicable law and judicial precedents, while interest remains for examination in the refund proceedings.
Notification-based restrictions on refunds of unutilized input tax credit for edible oils under an inverted duty structure operate prospectively from 18 July 2022. They do not deny refunds for credit accumulated before that date merely because a fresh application was filed later. A circular cannot retrospectively curtail an accrued input tax credit entitlement without statutory basis. Where a claim concerns the pre-notification period and is filed within the limitation period, rejection based solely on the later filing date is unsustainable. Refund claims require fresh consideration under applicable law and judicial precedents, while interest remains for examination in the refund proceedings.
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