Through a notification dated 23.03.2020 it has been provided that where a registered person has claimed refund of any amount of tax wrongly paid or paid in excess for which debit has been made from the electronic credit ledger, the said amount, if found admissible, shall be re-credited to the electronic credit ledger by the proper officer by an order which allow to curb the practice of voluntarily paying more tax or wrong tax from out of ITC, to encash such accumulated ITC by way of claiming refund in cash. It has also been specified as to how to find out whether any particular tax liability was paid out of Electronic Credit Ledger or through Electronic Cash ledger and payments are made on a consolidated manner on the due date. Where, he shall make an order sanctioning the amount of refund to be paid, in cash, in proportion to the amount debited in cash against the total amount paid for discharging tax liability for the relevant period, mentioning therein the amount adjusted against any outstanding demand under the Act or under any existing law and the balance amount refundable and for the remaining amount which has been debited from the electronic credit ledger for making payment of such tax, the proper officer shall re-credit the said amount as Input Tax Credit in electronic credit ledger. It may be noted that the above restriction would not apply for refund of ITC on account of zero-rated supplies and deemed exports. As per new Rule, the zero-rated supply shall be limited to 1.5 times of the domestic price of such goods supplied either by the same supplier or similarly placed supplier, which act as a check on over invoicing of export to claim more refund. But, when the refund claimant is not at all having domestic sale of same goods, the price of "similarly placed suppliers" have to be compared for this purpose, which is likely to lead to litigation on "similarity". The realisation of export proceeds has been mandatory, failing which the refund sanctioned can be recovered. However, the definition of "export of goods" does not provide receipt of export proceeds, imposing it as a condition for claiming refund of unutilised ITC and refund of IGST paid on exports, does not seem to be legal. Further, Section 16(3) of the IGST Act, which grants these benefits for export, does not make realisation of export proceeds as a condition precedent, though it mentions "in accordance with the provisions of Section 54 or the rules made thereunder".