Inverted duty refunds cover distinct manufacturing inputs, while administrative clarifications on identical goods do not bar eligible claims.

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....Unutilised input tax credit accumulated from an inverted duty structure is refundable where manufacturing inputs are taxed at a higher rate than the outward supply and are distinct from the finished goods. For Agarbati manufacturing, perfumes, fragrances, chemicals, packaging materials and cardboard qualify as inputs whose higher tax rates may support refund eligibility. A CBIC clarification addressing situations where input and output supplies are the same goods does not restrict such claims. CBIC circulars bind central tax officers but not the Appellate Tribunal, although they may carry persuasive value.....