VKC Footsteps (Inverted duty refund)
Facts
Refund of unutilised ITC where input GST rate exceeds output GST rate (inverted duty structure).
Issue
Whether ITC accumulated on input services is refundable along with that on input goods?
Held
No. Section 54(3) limits refund of unutilised ITC to that arising on input goods alone, not input services.
Ratio
Statutory restriction on refund cannot be rewritten by courts.
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