Let me start with a situation a lot of manufacturers will recognise. You purchase your raw materials under a very high GST rate and sell your product at a very low GST rate. As time goes on, you accumulate credit in your GST ledger month after month, and yet not even a single penny reaches your bank account.
The 57th GST Council meeting on 8 October 2026 has recommended some changes that could help with exactly this. Some of them will begin implementation from 1 November 2026, whereas, the others will start being active from 1 April 2027, and there are a few still requiring legal frameworks to be in place for them to start working.
So let’s walk through it together.
First, What Is an Inverted Duty Structure?
It just means the GST rate on what you buy is higher than the GST rate on what you sell. You pay more tax going in than you collect going out.
Since the excess remains in your input tax credit (ITC) balance, the CGST Act, under section 54(3), indeed, provides you a possibility to ask for a refund. However, the refund has mainly been limited tax paid on inputs goods till now, and that is why this exclusion of input services and capital goods from the refunds caused a lot of problems.
Example: Say you buy raw material worth ₹1 crore and pay 18% GST. That’s ₹18 lakh of credit. You sell the finished goods for ₹1.3 crore at 5%, so your output tax is ₹6.5 lakh. The other ₹11.5 lakh of credit has nowhere to go. We’ve kept this simple. The actual refund is worked out using the formula in Rule 89(5).
So What Did the Council Actually Recommend?
Four things matter here. Each one has its own date, so please don’t mix them up.
1. Input Services Come In From 1 November 2026
The refund will now extend to accumulated ITC on input services. But only for credit you avail on or after 1 November 2026. Older credit stays outside.
Insight: Start tracking your input service credit by the date you availed it. You’ll need that split when you file.
2. 90% Provisional Refund
Previously, the temporary refunds allowed by Section 54(6) were meant for supplies with zero rate. Besides these supplies, eligible inverted duty claims will also be a part of the provisional refunds as of 1 November 2026. You can claim 90% of it in advance, while the rest will come after the officer completes his checks.
3. Less Paperwork, Faster Handling
Acknowledgment or Deficiency Memo time gets reduced from 15 days to 10 days, while for Zero-rated and Inverted Duty Claims, the uploaded scanned documents of Form RFD-01 will be discontinued; instead, the computer system will directly extract the needed data. The approval of the eligible Claims will then take place automatically, based on identified risks.
In certain cases, they have even reduced it to 3 working days for 90% clearance. However, we are only taking it as a possible goal until the formal letter comes out confirming the same.
Fact: Automated sanctioning is expected to cover future claims. Claims that are already pending are not part of it.
4. Plant and Machinery From 1 April 2027
Until now, the tax paid on plant and machinery has been non-refundable. That rule will no longer apply at least for inverted duty claims. The refund will be one-sixtieth of the total credit per month, and it includes credit availed on or after 1 April 2027.
Example: Suppose you avail ₹36 lakh of credit on a new machine. You would get ₹60,000 a month for 60 months. It’s not a lump sum, so plan your cash flow around the instalments.
A Few Things We’d Watch Out For
- Services help only when inputs are the issue. Reports say the benefit applies where the higher rate sits on raw materials. If the inversion exists only on input services, there is no refund.
- A recommendation is not law yet. The input services and capital goods changes need amendments to Section 54(3) and the CGST Rules. The Section 54(6) change is notified from 1 November. Check each notification before you file.
- Dates matter. Only credit availed on or after the cut-off dates counts. Old balances won’t get relief.
- Matching can hold you up. The system is expected to match invoices between suppliers and buyers. If your supplier files late or wrongly, your claim could stall even when your own paperwork is clean.
Who Benefits the Most?
Businesses that spend a lot on services but sell at a low GST rate will see the most significant impact. Those capital intensive manufacturers contemplating acquiring more machinery by April 2027 should watch closely. Even those who find themselves a bit short of working capital may feel the impact by a 90% refund.
However, this change is unlikely to have much impact on you if you sell at the same rate as you buy or higher..
What We’d Do Before the Month Ends
- Split your ITC ledger by goods, input services and capital goods, and by the date you availed the credit.
- Reconcile GSTR-2B with your books and call the suppliers whose filings look off.
- Run the Rule 89(5) numbers and see whether your inversion comes from goods or only from services.
- Look at when you avail credit on big purchases planned around April 2027.
- Wait for the notifications and circulars before you change how you file refund claims.
Final Thoughts
If your business has credit stuck, it severely impacts on your cash flow and these measures get straight down to this issue. Not everything is final yet, and the details will come out through notifications over the next few months. The businesses that benefit most will be the ones with clean credit records when the rules go live.
This is where JD Shah Associates can guide you. Our GST and Indirect Tax team can review your ITC ledger, check whether your business actually qualifies for an inverted duty refund, reconcile your credit with GSTR-2B, and prepare your refund claims so they go in clean the first time. Once the notifications are out, we will tell you what applies to your business and what doesn’t.
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