COMMON ORDER

In these three writ petitions, which pertain to different and distinct assessment periods, the common petitioner assails three separate deficiency memos issued by the respondent.

2. The petitioner states that it is a textile manufacturing company, which uses viscose yarn as a raw material for the manufacturer of viscose fabrics. Since the tax paid on viscose yarn exceeds the tax payable on supplies by the petitioner, the petitioner asserts that there is unutilized Input Tax Credit (ITC) as a result of the inverted duty structure. By way of explanation, the petitioner points out that the raw material is taxed at 12%, whereas the final product is taxed at 5%.

3. In addition to the above, the petitioner states that it undertook export sales and that it is entitled to refund of IGST since such sales are zero rated. Earlier, the petitioner applied for and received refund as regards IGST. When the petitioner applied for refund with regard to unutilized ITC arising from the inverted duty structure, the application was rejected by the impugned deficiency memos. The present writ petitions were filed in the said facts and circumstances.

4. Learned counsel for the petitioner invited