Inverted-duty-structure refunds remain available for unchanged-rate apparel supplies despite trader status and require tax-period-specific computation and verified credit.

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....Accumulated input tax credit refunds under an inverted duty structure depend on the tax rates applicable to supplies, not on whether the registered person is a manufacturer or trader. A circular addressing accumulation caused by a GST rate reduction on the same goods does not exclude refunds for finished apparel supplied at an unchanged rate; higher-taxed inputs may remain eligible under the prescribed formula. Refunds must be computed tax-period-wise, and period-specific calculation satisfies that requirement. Verification must address ineligible credit, invoice reconciliation and credit relating to zero-rated supplies; unsupported objections do not displace findings based on examined records. The refund claims were sustained and the Revenue appeals dismissed.....