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of <h1>Refund of accumulated unutilized ITC under Section 54(3) and Rule 89: eligibility, exclusions, and procedural limits</h1> Where inputs attract higher tax than outputs, accumulated unutilized input tax credit (ITC) may be refundable under section 54(3) subject to exclusions (e.g., drawback claimed, exports subject to export duty, specified services involving land value) and procedural requirements under Rule 89 including invoice reconciliation, electronic debits and FORM GST RFD-01. Refund computation follows the Rule 89 formula limiting refund to a proportion of inverted-rated turnover and net ITC, with refunds restricted to ITC on inputs (not input services) per notifications. Guidelines require uploading GSTR-2A, Annexure-B details and supporting invoices. Recent judicial decisions have struck down parts of administrative circulars restricting eligibility, affecting retrospective application.
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