Assessee was earlier engaged in manufacturing taxable goods under regular rate structure. W.e.f. 22-09-2025, output GST rate was reduced while input tax rates remained unchanged, resulting in inverted duty structure.
Certain inputs were lying in closing stock as on 22-09-2025 on which ITC had already been availed in earlier tax periods. These old-stock inputs will now be consumed after 22-09-2025 for manufacturing goods taxable at lower inverted rate.
Whether refund of accumulated ITC under Section 54(3) read with Rule 89(5) can be claimed in respect of such old-stock inputs consumed during inverted duty period, even though ITC on those inputs was availed prior to commencement of inverted duty structure?
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