https://www.taxtmi.com/caselaws?id=800134 Accumulated input tax credit arising from higher-taxed packing materials used to market bulk sulphur in customised packets falls within the inverted duty refund mechanism under Section 54(3)(ii) of the CGST Act. Packing materials constitute business inputs even where the principal input and outward supply of sulphur attract the same GST rate. Where packing materials bear a higher GST rate than the outward supply, the resulting accumulated credit is refundable. Departmental circulars concerning identical input and output supplies cannot impose restrictions not contained in the statute, as implementation directions cannot curtail a statutory refund entitlement. en-us Wed, 30 Sep 2026 00:00:00 +0530 Thu, 01 Oct 2026 10:23:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800134 Accumulated input tax credit arising from higher-taxed packing materials used to market bulk sulphur in customised packets falls within the inverted duty refund mechanism under Section 54(3)(ii) of the CGST Act. Packing materials constitute business inputs even where the principal input and outward supply of sulphur attract the same GST rate. Where packing materials bear a higher GST rate than the outward supply, the resulting accumulated credit is refundable. Departmental circulars concerning identical input and output supplies cannot impose restrictions not contained in the statute, as implementation directions cannot curtail a statutory refund entitlement. Case-Laws GST Wed, 30 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800134