Refund of accumulated Compensation Cess input tax credit on coal...

Refund of accumulated Compensation Cess input tax credit on coal used to manufacture leather products for domestic supplies requires independent satisfaction of statutory refund conditions for an inverted tax structure. Eligibility to avail such credit, and the absence of a blocked-credit restriction, do not by themselves establish entitlement to a cash refund. Inability to utilise the credit against other liabilities cannot independently create a refund right, and the refund formula or procedure cannot create substantive entitlement where statutory conditions are unmet. Clarifications concerning zero-rated supplies did not establish eligibility for the domestic supplies. The appellate order allowing the claims was set aside and the rejection orders were restored.