Implication of amendment in definition of 'turnover of zero-rated supply of goods'

I record my appreciation at the outset, for a clear and detailed analysis.These are my short comments. 1. The object of the amendment, to my mind, is to link the refund claim of ITC to 1.5 times of the domestic value of export goods through the pre-existing formula.2.It looks unfair enough to leave the Adjusted Turnover, unadjusted,i.e without aligning it with the value of export goods as in the numerator of the formula.Here, your example nicely brings out the anomaly.3. They should have tweaked the definition of Adjusted Turnover for the purpose of Rule 89(4)(C) to save the exporters from a double whammy effect, by keeping lesser of the two, namely 1.5 times of the value of the domestic equivalent on the numerator while keeping the higher of the two namely the actual export value of goods itself in the denominator, which is not at all correct. 4. The round about argument on like goods, won't hold water,as there has to be some alternate means of equating the value of domestic clearances when not available to a fictional value as deemed fit. To the above extent, I sincerely expect an amendment but no further. K.Srinivasan(IRS)

srinivasan krishnamachari 28/07/2020