The petitioners challenged rejection of refund of accumulated compensation cess paid on coal used for manufacturing goods exported on payment of IGST. The factual background showed reliance by authorities on circulars restricting refund of cess.
The Court held that provisions of the Compensation to States Act permit availment and refund of cess credit on zero-rated supplies. Circulars contrary to statutory provisions were held to be unsustainable. The refund rejection orders were quashed.