In short
From 1 November 2026, GST refunds for businesses stuck in an inverted duty structure got bigger: input-service credit now counts in the refund formula, and capital-goods credit joins from 1 April 2027. For a manufacturer with ₹30 lakh of net ITC, that can mean roughly ₹4.8 lakh more refund on the same sales. The change comes from Notification No. 05/2026–Central Tax, dated 26 October 2026. Verified November 2026 · TaxGST.in
Meena makes cotton shirts in Tiruppur. She pays 18% GST on the dyes, chemicals and job-work that go into every shirt — but the shirts themselves are taxed at 5%. Every month, more tax goes in than comes out, and the difference piles up as unusable credit on the portal. Until October, only the credit on physical inputs counted towards her refund. The credit on services — the dyeing job-work, the transport, the testing lab — was simply left out.
That changed on 1 November 2026. Here’s what the new rule does, who gains, and how to work out your own number.
What an inverted duty structure actually is
An inverted duty structure arises when the GST rate on your inputs is higher than the rate on your finished goods or services. Classic cases: textiles (5% output vs 18% inputs), footwear, fertilisers, and several food and pharma products. Credit accumulates because you can never use it all against your output tax — so section 54(3)(ii) of the CGST Act lets you claim a refund of the accumulated input tax credit.
The refund is calculated under Rule 89(5) of the CGST Rules. And that rule is exactly what changed.
What changed on 1 November 2026
As per Notification No. 05/2026–Central Tax, dated 26 October 2026 — the CGST (Amendment) Rules, 2026, following the recommendations of the 57th GST Council meeting on 8 October 2026 — Rule 89(5) was substituted. The headline changes:
| Change | Before 1 Nov 2026 | From 1 Nov 2026 |
|---|---|---|
| Input services in Net ITC | Excluded — only inputs (goods) counted | Included, for ITC availed on or after 1 Nov 2026 |
| Capital goods in Net ITC | Excluded | Included from 1 Apr 2027, at 1/60th per month over 60 months |
| 1.5x “like goods” cap (Rule 89(4)(C)) | Zero-rated goods turnover capped | Cap removed |
| 90% provisional refund (section 54(6)) | Written into law only for zero-rated supplies | Extended to inverted duty refunds |
| Acknowledgement / deficiency memo (Rule 90) | 15 days | 10 days |
The new formula itself is unchanged in shape — only the “Net ITC” inside it is bigger:
Maximum Refund = (Turnover of inverted rated supplies × Net ITC ÷ Adjusted Total Turnover) − Tax payable on inverted rated supplies
Net ITC now means ITC on inputs plus eligible input services, and from April 2027, ITC on capital goods attributable to the relevant period. One condition to note: the inversion must come from the rates on input goods versus your output. Input services alone don’t create an inverted structure — they only add to the refund once the inversion exists.
This fixes a distortion the Supreme Court flagged years ago in the VKC Footsteps ruling, where services credit was left out of the refund even though businesses genuinely bore the tax. For the full picture of the November reform package, see our GST reforms rolling out from 1 November 2026.
A worked example: ₹4.8 lakh more on the same sales
Take a manufacturer with these figures for one refund period:
| Figure | Amount |
|---|---|
| Turnover of inverted rated supplies | ₹1,20,00,000 |
| Adjusted total turnover | ₹2,00,00,000 |
| Net ITC — inputs (goods) only | ₹22,00,000 |
| Eligible input services ITC (availed on/after 1 Nov 2026) | ₹8,00,000 |
| Tax payable on inverted rated supplies | ₹6,00,000 |
Old formula (inputs only): (₹1.2 crore × ₹22 lakh ÷ ₹2 crore) − ₹6 lakh = ₹13.2 lakh − ₹6 lakh = ₹7,20,000.
New formula (inputs + input services): (₹1.2 crore × ₹30 lakh ÷ ₹2 crore) − ₹6 lakh = ₹18 lakh − ₹6 lakh = ₹12,00,000.
Same sales, same tax paid — ₹4,80,000 more refund. And from April 2027, the capital-goods credit on the new machinery joins the same calculation, spread at 1/60th per month. If your business carries a big accumulated-credit balance, the full GST hub has the refund and ITC guides to work through before you file.
Who gains — and who doesn’t
Gains most: manufacturers in textiles, footwear, fertiliser and food processing with heavy service inputs — job-work, dyeing, testing, transport, packaging services — and a large accumulated credit balance. MSME manufacturers are the group the Federation of Indian Micro and Small & Medium Enterprises (FISME) specifically flagged as benefiting.
Gains later: businesses that bought plant and machinery recently — their capital-goods credit only enters the formula from 1 April 2027, and only for credit availed on or after that date, at 1/60th per month.
Doesn’t gain: businesses with no real inversion — if your output rate is equal to or higher than your input rates, there is no inverted duty refund at all, and adding services to Net ITC doesn’t create one. Also, credit blocked under section 17(5) (motor vehicles, food, personal expenses and the rest) stays excluded, and Rule 42/43 reversals still have to be made first.
What to do before your next refund claim
- Split your ITC ledger now. Tag input-services credit availed on or after 1 November 2026 separately from earlier credit — only the post-1-November services credit counts. Your ERP or accounting master needs this split before the claim period, not after.
- Recompute the last period under both formulas. If you filed an inverted-duty claim for a period ending before 1 November, the old formula still governs it — the notification doesn’t say how pre-November periods are recomputed. Don’t refile old claims on the new formula without advice.
- Check your 2B discipline. Refund claims still depend on the credit actually appearing in GSTR-2B. If ITC isn’t showing up, our 7 reasons ITC goes missing from GSTR-2B — and the fix for each is the place to start.
- Expect faster acknowledgement. The officer now has 10 days, not 15, to issue RFD-02 (acknowledgement) or RFD-03 (deficiency memo). If a deficiency memo does land, our GST refund process guide explains how to respond and escalate.
- Plan the capital-goods piece for April 2027. Machinery bought from 1 April 2027 onwards will feed the formula at 1/60th a month — if a big purchase is planned, the timing of the purchase now has a refund consequence too.
FAQs
From when does input-service credit count in inverted duty refunds?
From 1 November 2026, for ITC on input services availed on or after that date. Credit availed before 1 November 2026 doesn’t count, even if the refund claim is filed later.
When does capital-goods credit join the refund formula?
From 1 April 2027, for ITC availed on or after that date, spread at 1/60th of the eligible credit per month over 60 months.
Does the change help exporters too?
Yes — capital-goods credit is also added to Net ITC for zero-rated supplies under bond/LUT from 1 April 2027, and the 1.5x like-goods cap on zero-rated goods turnover was removed from 1 November 2026.
Can I claim a refund if only my input services are taxed higher than my output?
No. The inversion must exist between input goods and your output supplies. Input services only increase the refund once a genuine inverted structure exists.
How fast will I get the money?
The 90% provisional refund under section 54(6) now applies to inverted duty claims as well, and the acknowledgement window is down to 10 days. The balance follows after verification.
Sources
Notification No. 05/2026–Central Tax, dated 26 October 2026 (CGST (Amendment) Rules, 2026), issued by the Central Board of Indirect Taxes and Customs, substituting Rule 89(5) of the CGST Rules, 2017; Notification No. 03/2026–Central Tax, dated 26 October 2026; recommendations of the 57th GST Council meeting, 8 October 2026. The refund framework sits in section 54(3)(ii) and section 54(6) of the CGST Act, 2017. To pay any GST arising alongside a refund claim, use our step-by-step guide to paying GST online with a PMT-06 challan.
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