Input Tax Credit refund: prior IGST refunds do not bar unutilized ITC claims; supporting evidence required for reconsideration.

The court analysed entitlement to refund of unutilized Input Tax Credit under an inverted duty structure and held that prior IGST refunds for zero-rated supplies do not automatically bar a Section 54 refund claim; absence of debit entries alone cannot justify rejection. The decision emphasises the requirement to submit comprehensive supporting documents distinguishing inputs affected by the inverted duty structure and directs reconsideration allowing additional evidence and a reasoned order consistent with statutory conditions and principles of natural justice.

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