Inverted duty structure: exclude trading turnover from both Net ITC and adjusted turnover to preserve proportional refund calculation.
Refund computation under Rule 89(5) for inverted duty structure should not exclude input tax credit attributable to trading sales from Net ITC without also excluding the corresponding trading turnover from the "turnover of inverted rated supplies" and "adjusted total turnover." Circular guidance states Net ITC covers ITC on all inputs irrespective of rates, and treating inputs as trading purely by matching HSN codes risks distorting the prescribed proportional refund formula and producing disproportionate reductions. (AI Summary)

Transitional GST credit protection - genuine filing errors from technical glitches should not extinguish taxpayers' accumulated credit.
The court held that systemic technical glitches and rapid transition to the electronic GST regime prevented many taxpayers from filing TRAN 1 error free, and that relief limited to those able to produce specific digital evidence was irrational. It emphasised that genuine, inadvertent omissions should not extinguish taxpayers' entitlement to carry forward transitional credits and that the absence of an effective rectification mechanism necessitates procedural accommodations-including reopening electronic portals or allowing manual submission-to enable claiming of accumulated credits. (AI Summary)