Refund of unutilised input tax credit under the inverted duty...

Refund of unutilised input tax credit under the inverted duty structure remains available under section 54(3) where accumulation results from higher tax on certain inputs than on output supplies. Circular No. 135/05/2020 does not bar such a claim merely because one principal input and the output supply attract the same tax rate. The refund application must be considered under section 54(3), and time spent pursuing writ proceedings is excluded when calculating the limitation period.