Inverted duty refunds cover credit accumulated from higher-rated ancillary inputs, despite equal tax rates on principal input and output.

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....Refund of accumulated unutilised input tax credit under an inverted duty structure is available where higher-rated ancillary inputs, including chemicals and packing materials, cause credit accumulation, even if the principal input and output supply attract the same tax rate. Section 54(3) does not distinguish between major and minor inputs. The prescribed refund computation applies under Rule 89(5), and the discussed circular restricting refunds to cases involving higher-rated principal inputs had been declared unconstitutional. The text states that rejected refund claims were to be processed and sanctioned with applicable interest after personal hearing.....