Inverted tax structure refund affirmed where input tax rate exceeds output rate despite identical input-output supplies.
A refund of unutilized input tax credit under the refund provision is available when the tax rate on input supplies exceeds the tax rate on output supplies. An administrative circular denying refunds where input and output supplies are identical, even if the input rate is higher, conflicts with the clear statutory text and must be disregarded, preserving refund entitlement in such rate-comparison situations. (AI Summary)

Differential GST treatment for exports: distinct refund, documentation and valuation rules depending on tax payment status.
Differential GST treatment distinguishes exports made under a bond/LUT without payment of tax from exports with tax paid: the former requires LUT/bond and Form GST RFD-11, uses Form GST RFD-01 for refunds, mandates additional declarations and restricts zero-rated turnover to 1.5 times domestic like-goods turnover with refund value as the lower of invoice or shipping bill value; input tax credit on capital goods is not refunded and recovery applies for unrealised export proceeds. Exports with tax paid do not face these procedural or turnover restrictions and allow refund of capital goods ITC, with refund processed through a deemed shipping bill mechanism. (AI Summary)