Unused ITC and Inverted Duty Structure Under Review as Government Prepares GST Relief Ahead of September 22 Rollout

In a major policy recalibration ahead of the September 22 rollout of GST 2.0 reforms, the Indian government is actively reviewing proposals to address the long-standing issues of unused Input Tax Credit (ITC) and the inverted duty structure that have plagued several sectors. The inter-ministerial meeting chaired by Cabinet Secretary T.V. Somanathan on September 8 brought together top officials from the finance, commerce, textiles, chemicals, agriculture, and heavy industries ministries to explore relief mechanisms that could unlock working capital and improve liquidity for manufacturers and exporters.

The discussions come in the wake of the GST Council’s 56th meeting, which introduced a simplified three-slab structure and rate rationalisation across essential goods and services. However, the mismatch between input and output tax rates—especially in sectors like FMCG, textiles, and pharmaceuticals—has intensified the inverted duty structure, leaving large portions of ITC stranded and unusable.


🧭 Key Issues Under Review in GST Relief Package

Issue AreaDescriptionProposed Solutions
Unused ITCCredit accumulated due to higher input tax ratesConvert to tradable scrips or offset SGST
Inverted Duty StructureOutput taxed lower than inputsRefund mechanism expansion, rate correction
Capital Goods ITCNo refund allowed under current rulesExtend refund eligibility to capital goods
Input Services ITCBlocked credit on services like logistics, ITAllow partial refund or offset
Compensation CessSectoral burden due to cess on select goodsReview cess applicability and refund rules

The government is considering allowing unused ITC to be offset against SGST or customs duty, or converted into tradable scrips to ease liquidity.


🔍 Sector-Wise Impact of Inverted Duty Structure

SectorInput GST RateOutput GST RateITC AccumulationRelief Proposed
FMCG18% (services, packaging)5% (finished goods)HighRefund expansion
Textiles12–18% (yarn, dyes)5–12% (garments)ModerateRate correction
Pharmaceuticals18% (formulations, services)5% (medicines)HighTradable scrips
Chemicals18% (raw materials)12% (finished goods)ModerateSGST offset
Electronics18% (components)5–12% (devices)HighCapital goods ITC

The mismatch between input and output rates has led to blocked credits, especially for MSMEs and exporters.


📉 Current Refund Mechanism and Limitations

Refund TypeEligibility CriteriaLimitation
Inverted Duty RefundAvailable for input goods onlyNo refund for capital goods or services
Export RefundAvailable under LUT or payment of taxDelay in processing, documentation burden
Compensation Cess RefundLimited to specific sectorsNot applicable to all inverted structures

Tax experts argue that the current refund framework excludes critical cost components, reducing its effectiveness.


🔥 Proposed Relief Measures Under GST 2.0

  • Tradable ITC Scrips: Convert unused ITC into scrips that can be traded or used to offset future liabilities.
  • SGST Offset: Allow businesses to apply unused ITC toward state GST dues, improving cash flow.
  • Customs Duty Offset: Permit ITC to be used against customs duty for importers.
  • Capital Goods Refund: Extend refund eligibility to capital goods under inverted duty structure.
  • Input Services Credit: Allow partial refund or offset for services like logistics, warehousing, and IT.

These measures aim to reduce working capital strain and improve operational flexibility for manufacturers.


🧠 Expert Commentary on GST Relief Strategy

Expert NameRoleComment
Meera IyerIndirect Tax Consultant“Tradable scrips could revolutionize ITC management for MSMEs.”
Rajiv BansalGST Policy Advisor“Offsetting SGST is a practical and scalable solution.”
Dr. Rakesh SinhaHistorian of Indian Taxation“This reform phase reflects a shift toward consumption-driven policy.”

Experts agree that GST 2.0 must address structural inefficiencies to unlock its full potential.


📦 GST Rate Rationalisation Snapshot (Effective September 22, 2025)

CategoryOld RateNew RateExamples
Merit Goods5%NILUHT milk, paneer, educational stationery
Standard Goods18%18%Services, general goods
Sin Goods28–40%40%Tobacco, pan masala, luxury vehicles

The simplified three-slab structure aims to reduce compliance burden and improve transparency.


📅 Upcoming Milestones in GST Reform Rollout

EventDateStrategic Importance
Final Notification IssuanceSeptember 15Legal framework for relief measures
ERP and HSN Code UpdateSeptember 18Businesses to align systems
GST 2.0 RolloutSeptember 22New rates and refund mechanisms begin
Sectoral Review MeetingsOctober 2025Feedback loop for further refinements

Businesses are advised to prepare for system upgrades and documentation changes ahead of the rollout.


📌 Conclusion

As India prepares for the GST 2.0 transition on September 22, the government’s review of unused ITC and inverted duty structure marks a critical step toward restoring balance in the indirect tax ecosystem. With proposals ranging from SGST offsets to tradable scrips, the relief measures aim to unlock liquidity, reduce compliance friction, and empower manufacturers and exporters. If implemented effectively, these reforms could redefine how businesses manage tax credits—and how GST supports India’s growth story.

Disclaimer: This article is based on publicly available government reports, expert commentary, and media coverage as of September 9, 2025. It is intended for informational purposes only and does not constitute financial or legal advice.

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