Packing materials used to market packaged tea qualify as inputs...

Packing materials used to market packaged tea qualify as inputs used in the course or furtherance of business, without a statutory distinction between principal and ancillary inputs. Their higher tax rate, despite bulk and packaged tea attracting the same rate, supports refund of accumulated input tax credit under the inverted duty structure. Circulars addressing rate reductions on the same goods at different times and supplies under concessional notifications do not apply to this situation. Executive circulars cannot expand or restrict statutory refund entitlement. Revenue appeals challenging refunds of accumulated input tax credit on eligible packing materials were dismissed.