Arawali Engineers vs Union Of India (2026:Rj-Jd:17161-Db) on 13 April, 2026

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    Rajasthan High Court – Jodhpur

    Arawali Engineers vs Union Of India (2026:Rj-Jd:17161-Db) on 13 April, 2026

    [2026:RJ-JD:17161-DB]
    
    
    
          HIGH COURT OF JUDICATURE FOR RAJASTHAN AT
                           JODHPUR
                   D.B. Civil Writ Petition No. 10937/2021
    
    Arawali Engineers, F-669, Basni Phase-Ii, Marudhar Industrial
    Area, Jodhpur, Rajasthan.
                                                                           ----Petitioner
                                          Versus
    1.       Union of India, Through Secretary, Department Of
             Revenue, Ministry of Finance, Government of India, New
             Delhi.
    2.       The Additional Commissioner (Appeals), CGST And
             Central Excise Duty Commissionerate, G-105, Road No.
             5, New Jodhpur Industrial Area Near Diesel Shed,
             Jodhpur.
    3.       The Assistant Commissioner, Central Goods And Service
             Tax Division-A, O2E/1, Subhash Enclave, Op. Af Central
             School No. 1, Abhaygarh Scheme, Jodhpur.
                                                                        ----Respondents
    
    
    For Petitioner(s)             :    Mr. Anil Bhansali
    For Respondent(s)             :    Mr. Kuldeep Vaishnav
                                       Mr. Nilesh Choudhary
    
    
                  HON'BLE MR. JUSTICE ARUN MONGA

    HON’BLE MR. JUSTICE SUNIL BENIWAL

    Order (Oral)

    SPONSORED

    13/04/2026

    Per: Arun Monga, J.

    1. The present writ petition is directed against the order dated

    14.10.2020 passed by the Assistant Commissioner (CGST),

    Jodhpur, whereby the refund claims of the petitioner came to be

    rejected, as well as the Order-in-Appeal dated 26.02.2021 passed

    by the Additional Commissioner (Appeals), Jodhpur, whereby the

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    appeal preferred by the petitioner against the said rejection was

    dismissed, affirming the order of the adjudicating authority.

    2. Brief facts of the present case are that the petitioner is a

    registered person under the Central Goods and Services Tax Act,

    2017 (hereinafter, “Act of 2017”) holding GSTIN No.

    08AABFA4724G1ZS, and is engaged in the business of

    manufacturing utensils. The rate of tax on inputs, namely steel

    patta, and input services such as job work is 18%, whereas the

    rate of tax on output supplies (utensils) is 12%, resulting in

    accumulation of unutilized input tax credit on account of an

    inverted duty structure. During the financial year 2019-20, such

    unutilized input tax credit accumulated for the four quarters

    amounted to Rs.11,76,757/-, Rs.23,27,504/-, Rs.3,37,201/-, and

    Rs.13,61,718/- respectively.

    2.1 In accordance with Section 54 of Act of 2017, the petitioner

    filed applications in prescribed form GST RFD-01 seeking refund of

    the aforesaid unutilized input tax credit within the stipulated time.

    However, the respondent No. 3 issued show-cause notices dated

    12.10.2020 for all four quarters, proposing to restrict the eligible

    input tax credit by excluding input services from the computation

    of “Net ITC.” The petitioner submitted detailed replies on

    13.10.2020, objecting to the proposed restriction.

    2.2 Subsequently, the respondent No. 3 rejected the refund

    claims vide orders dated 14.10.2020, holding that the petitioner

    had wrongly included input tax credit on input services in the

    computation of “Net ITC” in contravention of Rule 89(5) of the

    CGST Rules, 2017 and had also claimed credit on certain items

    allegedly not qualifying as inputs.

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    2.3 Aggrieved thereby, the petitioner preferred appeals under

    Section 107 of Act of 2017 before respondent No. 2, which came

    to be dismissed vide order dated 26.02.2021. The appellate

    authority upheld the interpretation that under amended Rule

    89(5), “Net ITC” is confined to input goods only. The petitioner’s

    claim, being one of refund arising out of inverted duty structure,

    was thus denied to the extent of input services.

    2.4 Hence, the present writ petition.

    3. Learned counsel for the petitioner submits that under Section

    54(3) of the Act of 2017, a registered person is entitled to refund

    of unutilized input tax credit where accumulation arises from an

    inverted duty structure, namely, where the tax on inputs exceeds

    that on output supplies. It is undisputed, even by the

    respondents, that the petitioner falls within this category. The

    accumulated balance reflected in the electronic credit ledger for FY

    2019-20 establishes such entitlement. Rejection of the refund

    claim is, therefore, contrary to the statute and unsustainable.

    3.1. It is further contended that the respondents wrongly denied

    the claim on the assumption that it included ITC on input services.

    The turnover, output tax liability, and ITC figures clearly show that

    the output tax liability on inverted duty turnover exceeds the ITC

    on input services, leaving no scope for refund of input service

    credit. Denial on this basis effectively restricts utilization of validly

    availed ITC without statutory authority.

    3.2. Learned counsel for the petitioner also submits that the Act

    does not contemplate any distinction between ITC on goods and

    input services once credit is validly availed, as all such credit

    merges into a common electronic credit ledger. The respondents,

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    therefore, fundamentally misconstrued the statutory scheme in

    treating the claim as one for refund of input service credit,

    whereas it was a claim for accumulated credit due to an inverted

    duty structure. The impugned orders thus deserve to be quashed.

    4. Learned counsel for the respondents opposes the petition. He

    submits that the appellate order, as on the date it was passed,

    was according to the then prevailing position of law and warrants

    no interference.

    5. Heard learned counsel for the parties and perused material

    available on record.

    6. At the outset, it transpires that the issue involved in the present

    writ petition is no longer res integra and stands conclusively

    settled by the Hon’ble Supreme Court in Union of India v. VKC

    Footsteps India Pvt. Ltd.1, whereby the finding given by Gujarat

    High Court in VKC Footsteps India Pvt. Ltd. vs. Union of

    India2 holding that Explanation (a) to Rule 89(5) of the CGST

    Rules was ultra vires Section 54(3) of the CGST Act, and directing

    inclusion of input services within “Net ITC” for refund purposes,

    was set aside. The Apex Court in fact upheld the view taken by

    Madras High Court in Tvl. Transtonnelstroy Afcons Joint

    Venture v. Union of India 3, wherein it was categorically held

    that Section 54(3)(ii) does not violate Article 14 and that

    restricting refund to unutilized ITC on input goods, while excluding

    input services, constitutes a valid classification and a permissible

    legislative policy.

    1
    . AIR 2021 SC 4407
    2
    . C/FA/39335/2018
    3
    . CW Case No. 11470/2019

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    7. On a court query, learned counsel for the respondent submits

    that at the time of rejection of the claim of the petitioners, the

    Department had proceeded on the premise of the judgment

    rendered by the Gujarat High Court dated 24.07.2020 in VKC

    Footsteps India Pvt. Ltd. vs. Union of India, (supra).

    8. He submits that the view taken by the Gujarat High Court

    was later clarified by the Supreme Court in Union of India vs.

    VKC Footsteps (supra). In light thereof, he fairly states that if

    the petitioner approaches the department, the competent

    authority shall now accordingly pass fresh order by considering

    the applicability of Supreme court judgment, ibid.

    9. In course of hearing, learned counsel for the petitioner has

    submitted a computation of refund in terms of Rule 89 (5) r/w

    Section 54(3) RGST and states that the same is in accordance

    with Supreme Court’s judgment. The computation chart as

    referenced above is reproduced herein below for ready reference:

                                         Ratio                           Output tax
              Inverted                     of                                on       ITC on
                                                                                                   TAX                 Refund    Refund
                duty        Total       IDT/T      ITC on      NET ITC    Inverted     Input                REFUND
    Quarter                                                                                      PAYABLE               Claimed   denied
              turnover   Turnover (3)     otal    Inputs (5)     (6)        duty      Services              DUE (10)
                                                                                                    (9)                  (11)     (12)
                 (2)                    Turno                            Turnover       (8)
                                        ver (4)                              (7)
    
    Apr
    2019 -
              44065861   48247909       0.914     5791630      5293550   5287903      1286555    4001348    1288273    1176757   1176757
    June
    2019
    Jul
    2019 -
              29038189   32522772       0.893     5237796      4677352   3484583      1453397    2031186    2645417    2327504   1374691
    Sep
    2019
    Oct
    2019 -
              38799948   45690758       0.850     5156151      4382728   4655993      724294     3931699    446931     337201    337201
    Dec
    2019
    Jan
    2020 -
              30526896   33550075       0.910     5259052      4785737   3663227      290461     3372766    1412395    1361718   322556
    Mar
    2020
    
    
    

    10. Be that as it may, in view of the aforesaid statement made

    by the learned counsel for the respondents, we are not going into

    the merits of the computation and the fresh decision is left open

    to be rendered by the competent authority after going through the

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    Union of India vs. VKC Footsteps (supra). However, it is

    expected that in case the competent authority disagrees with the

    computation chart, supra, a speaking order shall be passed giving

    specific reasons thereof, as expeditiously as possible.

    11. With the aforesaid observations and directions, the present

    petition stands disposed of.

    10. All pending application(s) also stand disposed of.

                                       (SUNIL BENIWAL),J                                              (ARUN MONGA),J
    
    
    
    
                                       Ashutosh-58
    
    
    
    
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