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of Refund of unutilised balance of Input Tax Credit (ITC) - Scope of amendment to rules - The 2022 Amendment Rules inserts a new stipulation for comparison between two values. Such an exercise was not contemplated prior to the amendment as what was taken into account was the actual transaction value. - The law is now no more res integra that mere use of the term explanation will not be indicative of the fact that the amendment is clarificatory/declaratory. - The amendment will have a prospective effect. - HC
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