Refund of accumulated input tax credit under an inverted duty...

Refund of accumulated input tax credit under an inverted duty structure depends on whether input taxes exceed the tax rate on output supplies under Section 54(3)(ii). The comparison is not confined to the principal raw material and may include ancillary business inputs taxed at higher rates. Common HSN classification of raw materials and finished goods does not by itself establish that they are the same goods. CBIC circulars addressing rate reductions on identical goods at different times, including concessional supplies, do not restrict a statutory refund where those circumstances are absent.