A 100% service exports company has gross billable income of 5.75 crores for FY 2018-19. It has LUT registration. Its total accumulated ITC for the year will be about 30 lakhs. It will be raising March 2019 invoices for this amount. However, since cash-flow wise, it does not need 5.75 crores as such, it may raise two invoices in march 2019 – one for say 2.50 cr. and another for 3.25 cr. Supposing by the time it files a refund application for ITC credits, only one invoice (3.25 ) has been paid (another may be paid a few months later), will it be granted full refund of ITC of 30 lakhs, or the refund will be pro-rated as 3.25:2.50?
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