Refund of accumulated ITC under an inverted duty structure

In a significant ruling on GST refund jurisprudence, the Court held that the amendment to Rule 89(5) correcting anomalies in the refund formula is curative and therefore retrospective. 

It rejected the Revenue’s reliance on Circular 181/2022 limiting the amendment prospectively, holding such clarification contrary to statutory intent and judicial direction. By aligning with Gujarat High Court precedents (affirmed by the Supreme Court), the Court emphasized that refund entitlement under Section 54 cannot be denied due to procedural interpretation of formula changes. 

The decision restores parity across taxpayers and ensures that legitimate refunds are not defeated by interpretational inconsistencies.