https://www.taxtmi.com/caselaws?id=783997 Refund of accumulated unutilised ITC due to an inverted duty structure was denied on the premise that refund under Section 54(3)(ii) of the CGST Act is barred where input and output are the same and that the rate comparison must be confined to "principal input" versus "principal output supply." Relying on its earlier decision in an identical fact situation, the HC held that Section 54(3)(ii) does not prohibit refund merely because input and output are the same, and the proviso does not mandate a principal input/principal output rate comparison or any further restrictive test beyond inverted rate incidence. The impugned orders were set aside and the refund claim was allowed. en-us Fri, 12 Dec 2025 00:00:00 +0530 Fri, 26 Dec 2025 07:18:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783997 Refund of accumulated unutilised ITC due to an inverted duty structure was denied on the premise that refund under Section 54(3)(ii) of the CGST Act is barred where input and output are the same and that the rate comparison must be confined to "principal input" versus "principal output supply." Relying on its earlier decision in an identical fact situation, the HC held that Section 54(3)(ii) does not prohibit refund merely because input and output are the same, and the proviso does not mandate a principal input/principal output rate comparison or any further restrictive test beyond inverted rate incidence. The impugned orders were set aside and the refund claim was allowed. Case-Laws GST Fri, 12 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783997