Attached is the news alert by GSTExpertise, decoding the impact of Circular No. 135/5/2020 - Clarification on refund related issues. The Circular though has provided some relief to the issues raised post issuance of Master Circular on Refund i.e. Circular 125 in Nov 2019, however the below questions are still unanswered:

• Clubbing of tax periods across financial years - If a taxpayer has filed 1 refund application covering period Jan to March 2020 and July to Sept 2020, can a separate refund application be filed for the intervening period i.e. April to June 2020?

• Refund of accumulated ITC due to reduction in tax rate - In case of a trader who sold goods under any concessional tax rate scheme i.e. there is no reduction in tax rate of goods, then whether benefit of Inverted duty tax structure is available to that trader?

• Refund of mis-match ITC prior to the insertion of Rule 36(4) - Introduction of Rule 36(4) introduced in October 2019 has restricted the availment of the mismatch credit to the extent of 20% (10% w.e.f 1 Jan 2020) of the matched credit. So, whether refund of this mis-match credit is available to the assessee pertaining to refund periods prior to 09 October 2019?

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