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 supply under an inverted tax structure depends independently on the conditions in Section 54(3); credit standing in the electronic credit ledger does not itself create a cash-refund right. Availability of credit, including the absence of a blocked-credit restriction, concerns credit availment rather than refund eligibility. Inability to use cess credit against other liabilities and the absence of cess on domestic output supplies do not establish inverted tax structure eligibility. Clarifications and export-related decisions concerning zero-rated supplies do not support the domestic refund claim. The refund-granting appellate order was set aside, restoring the original rejections.