Inverted duty refunds remain available where higher-taxed packing materials create accumulated ITC, despite restrictive administrative circulars.

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....Refund of unutilised input tax credit under an inverted duty structure remains available where higher-taxed packing materials used to make sulphur marketable in customised packets cause credit accumulation, even though the principal goods at input and output stages are identical. Statutory refund conditions do not exclude such claims based on identity of the principal goods. CBIC circulars issued for uniform implementation cannot add restrictions or curtail the statutory entitlement. The Tribunal upheld the taxpayer's refund and directed release of the sanctioned amount, dismissing the Revenue's appeal.....