GSTAT says Packing Materials Can Create Inverted Duty Refund

Dalmia Tea Packaging purchased bulk tea at 5% and packing materials at 12%/18%, and supplied packaged tea at 5%, resulting in accumulated ITC. GSTAT held that Section 54(3)(ii) looks at all inputs, not merely the principal input, and that CBIC Circular 135/2020 - dealing with inversion caused by a later rate reduction on the same goods - could not be applied to deny the refund.