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The two calculations are not interchangeable. Rule 89(4) uses ITC on inputs and input services as Net ITC. Rule 89(5) uses ITC on inputs for Net ITC and then applies a separate, proportionate deduction for tax payable on inverted-rated supplies. Your relevant tax period, filing date and the law in force for that claim also matter.
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At a glance: choose the route that matches the claim
| Question | Rule 89(4) | Rule 89(5) |
|---|---|---|
| What problem does it address? | Refund of eligible ITC relating to zero-rated supplies made without payment of tax under bond or LUT. | Refund of unutilized ITC accumulated because inputs are taxed at a higher rate than the outward, inverted-rated supplies. |
| Core formula | Zero-rated turnover multiplied by Net ITC, divided by Adjusted Total Turnover. | Inverted-rated turnover multiplied by Net ITC, divided by Adjusted Total Turnover, less a proportionate tax-payable deduction. |
| Net ITC for the sub-rule | ITC availed on inputs and input services during the relevant period. | ITC availed on inputs during the relevant period. |
| Special deduction | None in the formula stated in Rule 89(4). | Yes. Tax payable on the inverted-rated supplies is multiplied by Net ITC divided by ITC availed on inputs and input services. |
| Key timing issue | Use the definitions and conditions applicable to the relevant period. | The deduction term was substituted by Notification 14/2022-Central Tax dated 5 July 2022; older claims require a period- and filing-date-specific analysis. |
Both outputs are maximum admissible refund amounts. A formula result is not, by itself, a finding that the taxpayer qualifies or that the entire amount will be sanctioned.
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When Rule 89(4) applies
The qualifying claim
Rule 89(4) is the starting point for a refund claim based on zero-rated supplies made without payment of tax under a bond or LUT. The calculation allocates eligible ITC to the zero-rated turnover for the relevant period. A business that has an inverted rate on its domestic supplies, but has not made the type of zero-rated supply covered by this provision, should not select Rule 89(4) merely because it has unutilized credit.
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First identify the legal basis of the claim and the tax period. Then confirm that the supplies, bond or LUT position, and other statutory conditions match the requirements in force for that period. The rule number is a consequence of that classification, not a shortcut around it.
The Rule 89(4) formula
Refund amount = (turnover of zero-rated supply of goods + turnover of zero-rated supply of services) × Net ITC ÷ Adjusted Total Turnover
This is a ceiling calculated for the relevant period. The current rule text supplies detailed definitions for each turnover component, Net ITC, Adjusted Total Turnover and the relevant period. A spreadsheet that simply inserts total sales and total credit without applying those definitions can produce the wrong ceiling.
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What counts as Net ITC
For Rule 89(4), Net ITC means ITC availed on inputs and input services during the relevant period. That base is broader than the Net ITC base in Rule 89(5). Capital-goods treatment must be checked separately under the law applicable to the period; the government has announced a future change discussed below, but that change is not already part of the formula as of October 2026.
Build the zero-rated turnover correctly
The rule does not treat every accounting entry as turnover for the ratio. For services, the definition addresses eligible payments received during the relevant period, services completed in the period for which payment was received earlier, and deductions for advances connected with services that remain incomplete during the period. For goods, the current rule text imposes a value limitation. Use the statutory wording for the period rather than a simplified “invoice value” assumption.
Adjusted Total Turnover is also a defined term. Pull it from the same relevant-period framework used by the rule, and retain the working that shows how the denominator was assembled. A change in the denominator changes the refund ceiling even when the zero-rated sales and ITC figures stay constant.
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When Rule 89(5) applies
The inverted-duty situation
Rule 89(5) addresses accumulated unutilized ITC attributable to an inverted duty structure: the rate on relevant inputs is higher than the rate on the outward supplies to which the accumulation relates. The claim is not selected simply because a ledger shows a credit balance. You must connect the accumulation to inverted-rated supplies and apply the conditions and definitions for the relevant period.
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The current Rule 89(5) formula
Maximum refund = [(turnover of inverted-rated supply of goods and services × Net ITC ÷ Adjusted Total Turnover)] − [tax payable on those inverted-rated supplies × (Net ITC ÷ ITC availed on inputs and input services)]
The second bracket is essential. It is a proportionate deduction, not a subtraction of the entire tax payable. Notification 14/2022-Central Tax, dated 5 July 2022, substituted this deduction term. Any calculation based on an older version that subtracts all tax payable without the proportionate ratio is not the current text for periods to which the amendment applies.
Why the ITC denominators look different
For this sub-rule, Net ITC means ITC availed on inputs during the relevant period. However, the denominator in the deduction term refers separately to ITC availed on inputs and input services. Thus, a business cannot use its total input-and-input-service credit as Net ITC and then assume the deduction disappears. The two roles must be populated separately in the calculation.
Rule 89(5) borrows the denominator and relevant-period definitions used by Rule 89(4). That cross-reference does not merge the two formulas: the claim basis, Net ITC base and deduction remain distinct.
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The following numbers are purely illustrative. They show the mechanics of the statutory expressions, not an eligibility opinion or an estimate of any particular taxpayer’s refund.
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Illustration 1: Rule 89(4)
Assume that, after applying the rule’s definitions, a relevant period contains zero-rated goods turnover of ₹80 lakh and zero-rated services turnover of ₹20 lakh. Assume Net ITC (inputs plus input services) of ₹30 lakh and Adjusted Total Turnover of ₹150 lakh.
- Add the two zero-rated turnover components: ₹80 lakh + ₹20 lakh = ₹100 lakh.
- Multiply that turnover by Net ITC: ₹100 lakh × ₹30 lakh.
- Divide by Adjusted Total Turnover: ₹3,000 lakh² ÷ ₹150 lakh = ₹20 lakh.
On those assumptions, ₹20 lakh is the formula’s maximum admissible amount before applying the other statutory requirements and any verification of the figures.
Illustration 2: Rule 89(5)
Assume inverted-rated turnover of ₹100 lakh, Net ITC on inputs of ₹24 lakh, Adjusted Total Turnover of ₹200 lakh, tax payable on the inverted-rated supplies of ₹8 lakh, and total ITC on inputs and input services of ₹30 lakh.
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- Calculate the proportionate deduction: ₹8 lakh × (₹24 lakh ÷ ₹30 lakh) = ₹6.4 lakh.
- Subtract the deduction: ₹12 lakh − ₹6.4 lakh = ₹5.6 lakh.
The example demonstrates why omitting the second bracket overstates the result. It also shows why the input-only Net ITC figure and the broader input-plus-input-service denominator must be kept in separate fields.
A decision process for selecting the right formula
- Classify the legal basis. Write down whether the proposed refund concerns zero-rated supplies made without payment under bond or LUT, or unutilized ITC caused by an inverted duty structure. If neither description fits, stop and identify the correct provision before calculating.
- Fix the relevant tax period. Record the months or other period covered by the application and the date on which the application will be filed. Do not mix turnover or credit from different periods unless the rule expressly requires it.
- Choose the rule. Use Rule 89(4) for the qualifying zero-rated-supply route. Use Rule 89(5) for the inverted-duty route. Do not use one formula as a proxy for the other.
- Assemble defined turnover. Apply the period-specific definitions for zero-rated or inverted-rated turnover and for Adjusted Total Turnover. For services, check the payment and advance adjustments; for goods, check the current value limitation.
- Separate the ITC bases. For Rule 89(4), calculate Net ITC from inputs and input services. For Rule 89(5), calculate Net ITC from inputs only, and separately calculate total ITC on inputs and input services for the deduction denominator.
- Apply the formula in full. Include Rule 89(5)’s proportionate tax-payable deduction. Label the result as a maximum admissible amount, not an automatic sanction.
- Test historical-law issues. If the period or application falls around 5 July 2022, analyse the amendment, filing date, limitation rules, jurisdiction and applicable decisions before deciding which version to use.
- Retain the trail. Keep the turnover schedule, ITC ledger extraction, tax-payable computation, bond or LUT evidence where relevant, period reconciliation and the version of the rule relied upon.
How the two routes differ in practice
| Comparison point | Rule 89(4) | Rule 89(5) |
|---|---|---|
| Economic trigger | Zero-rated supply made without payment of tax under bond or LUT. | Credit accumulation attributed to an inverted duty structure. |
| Turnover in the numerator | Zero-rated supply of goods plus zero-rated supply of services, using the rule’s definitions. | Turnover of inverted-rated supply of goods and services. |
| Net ITC | Inputs and input services. | Inputs only. |
| Adjusted Total Turnover | Defined under the Rule 89 framework for the relevant period. | Uses the Rule 89(4) definition by cross-reference. |
| Tax-payable deduction | No equivalent deduction in the stated formula. | Tax payable on inverted-rated supplies multiplied by Net ITC divided by ITC on inputs and input services. |
| Principal historical concern | Period-specific definitions and eligibility. | Whether the 5 July 2022 substituted deduction applies to the claim, especially for older periods and applications. |
The 5 July 2022 amendment and older claims
Notification 14/2022-Central Tax dated 5 July 2022 changed the Rule 89(5) deduction. The amendment matters whenever a claim, period or litigation history overlaps the old and new wording. It is unsafe to apply the amended expression automatically to every historical claim, and it is equally unsafe to assume that every older claim must use the pre-amendment expression.
CBIC Circular 181/13/2022, dated 10 November 2022, treated the amended formula as prospective from 5 July 2022 and said it applied to applications filed on or after that date. The Telangana Commercial Taxes Department’s January 2026 handbook reports a different development: in Ascent Meditech Ltd., Special Civil Application No. 18317 of 2023, decided by the Gujarat High Court on 17 October 2024, the court quashed the circular to the extent it said the amendment was not clarificatory and treated the amendment as retrospective in that case, subject to the limitation discussion in the decision.
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The handbook is a useful summary, not a substitute for reading the judgment or checking later law. For an older claim, document at least:
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- the date the refund application was filed;
- the version of Rule 89(5) used in the original calculation;
- the applicable limitation analysis;
- the jurisdiction and any binding or persuasive decisions; and
- whether subsequent orders or notifications have altered the position.
Those facts can lead to a different answer for two taxpayers with similar turnover and ITC but different filing dates or jurisdictions. Describe the result as period-specific rather than announcing a universal prospective or retrospective rule.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Capital-goods ITC: announced change for 1 April 2027
A PIB FAQ published before this article’s October 2026 date reports that capital-goods ITC is to be included, to the extent attributable to the relevant period, in Net ITC for both Rule 89(4) and Rule 89(5) from 1 April 2027. As of 13 October 2026, that was a future-effective announcement, not a component that should be inserted into the current formula.
Before applying the change to a claim, confirm the underlying notification and detailed rules, including how “to the extent attributable to the relevant period” is to be computed. Claims covering periods before 1 April 2027 should not be recalculated as though capital goods were already included under the current wording.
Common errors and how to correct them
Using Rule 89(4) because the business exports
Export activity alone does not answer every eligibility question. Confirm that the claim is for the zero-rated supplies made without payment under bond or LUT and then apply the defined turnover and ITC terms.
Using Rule 89(5) for any unutilized credit
A credit balance is not automatically an inverted-duty refund. Trace the accumulation to the relevant inverted-rated supplies and establish the period-specific conditions before using the formula.
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Including input-service ITC in Rule 89(5) Net ITC
This is one of the most consequential classification errors. Keep input-service ITC out of the Rule 89(5) Net ITC numerator, while still including the prescribed inputs-and-input-services figure in the deduction denominator.
Leaving out the proportionate deduction
The current Rule 89(5) expression does not stop after the turnover-times-ITC term. Calculate the tax-payable bracket and subtract it. If an old workbook subtracts all tax payable, replace it with the substituted proportionate expression where applicable.
Applying a simplified turnover ratio
Service receipts, earlier payments for completed services, advances for incomplete services and the goods value limitation can change the numerator. Reconcile each component to the statutory definition instead of copying a sales total from the general ledger.
Treating a future announcement as current law
Do not add capital-goods ITC to the current Net ITC calculation solely because a government FAQ reports an effective date of 1 April 2027. Verify the notification and use the rules applicable to the claim period.
Ignoring the filing date in a historical dispute
The circular, amendment, court decision and limitation rules interact. Record the application date and obtain advice on the governing law for the relevant jurisdiction rather than relying on a one-line statement about all pre- or post-amendment claims.
Information to assemble before calculating
- The legal description of the supplies and the proposed refund basis.
- The exact relevant period and application date.
- Zero-rated or inverted-rated turnover split between goods and services where required.
- Adjusted Total Turnover calculated under the applicable Rule 89 definitions.
- ITC on inputs and input services, with input-only ITC separately identified for Rule 89(5).
- Tax payable on the inverted-rated supplies for a Rule 89(5) claim.
- Evidence of the bond or LUT route for a Rule 89(4) claim.
- The notification, circular and case-law position used for any period affected by the 5 July 2022 amendment.
- A reconciliation showing that every formula input belongs to the same relevant period and has not been counted twice.
What the formula can—and cannot—tell you
The arithmetic answers a narrow question: what maximum amount results from the prescribed turnover and ITC relationship for the selected route. It does not replace the legal eligibility test, the statutory definitions, period restrictions, limitation analysis or review of the evidence supporting the figures.
For a current claim, start with the official Rule 89 text in force for the relevant period. For a claim affected by the 2022 change, read the notification and assess the circular and court history in context. For a claim intended for a period beginning on or after 1 April 2027, confirm the final capital-goods provisions before changing the workbook.
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