Bill-to ship-to export refunds survive toll-data objections when undisputed transport and export records prove physical movement.

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....Refund of accumulated input tax credit on exported goods remains available where bill-to ship-to supplies are supported by undisputed e-way bills, transportation, export and banking records establishing delivery and export. GST law does not require movement to commence from the supplier's registered premises, and toll plaza receipts are not a mandatory condition for credit; toll data cannot override documentary proof of physical movement. Cancellation of upstream suppliers' registrations does not by itself invalidate credit where the direct supplier is validly registered and the claimant lacks involvement in upstream irregularities. Fresh allegations and unsupported evidence beyond the show cause notice cannot be raised at the Tribunal stage, absent exceptional circumstances under the applicable evidence rules.....