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Refund of taxes or accumulated ITC is a statutory right governed strictly by the provisions of Section 54. The Revenue cannot impose extra-statutory conditions, nor can executive circulars override or restrict statutory rights explicitly granted by the legislature.

Assistant Commissioner of Central Taxes v. Gemini Edibles and Fats India Ltd. [(2025) 143 GSTR 644 (SC)]: 
The Supreme Court affirmed that a circular cannot curtail a statutory right. Refund of unutilized ITC for inverted duty structure cannot be denied for accumulation prior to 18 July 2022 merely because the application was filed post that date.

Tata Steel Ltd. v. State of Jharkhand [2025:JHHC:10211-DB]: 
The Jharkhand High Court ruled that a refund claim (Compensation Cess ITC on coal used in exports) cannot be rejected on the basis of conditions (like 180-day payment proof) not sourced in the CGST Act, Rules, or binding circulars.

VKC Footsteps India Pvt. Ltd. v. Union of India [2021 (52) G.S.T.L. 513 (SC)]: Affirmed the constitutional validity of excluding "input services" from the inverted duty structure refund formula under Rule 89(5), establishing that Parliament has the latitude to restrict refund scopes.

Distinguishing Facts: 
The distinction lies in legislative restriction versus administrative restriction. VKC Footsteps upheld a restriction because it was legally enacted via Rules bridging the Statute, whereas Gemini Edibles and Tata Steel struck down restrictions that were merely administrative or extra-statutory.

How the Department May Distinguish: 
The Department will deny refunds if the taxpayer fails the doctrine of "Unjust Enrichment" as laid down in the landmark Mafatlal Industries Ltd. v. Union of India [1997 (89) ELT 247 SC], arguing the burden of tax was already passed to the consumer.