Inverted duty refunds include packaging inputs where administrative circulars cannot restrict statutory input tax credit entitlement.

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....Refund of unutilised input tax credit under an inverted duty structure extends to packing materials, labels, cartons and plastic containers used to market packaged tea. Section 54(3)(ii) treats such materials as inputs and does not distinguish between principal and ancillary inputs; comparison of bulk tea and packaged tea without considering packaging inputs is therefore incorrect. Circular No. 135/5/2020-GST addresses credit accumulation caused by a rate reduction on the same goods at different times and does not apply where bulk and packaged tea bear the same tax rate. Administrative circulars cannot add to or curtail the statutory refund entitlement.....