High Court of Gujarat3 September 2026

MAC Industry v. Union of India

For assessee

R/SPECIAL CIVIL APPLICATION NO. 1693 OF 2026

The ruling in brief

Where restriction in Rule 96(10) governing IGST refund on exports was omitted without a saving clause and both the SCN and consequential order were issued after such omission, restriction could not survive for pending or subsequent proceedings and related actions were to be quashed in alignment with Goodluck India Ltd. ruling

Provisions considered

Section 16 Integrated Goods and Services Tax Act, 2017 - Section 54 of Central Goods and Services Tax Act, 2017/ Gujarat Goods and Services Tax Act, 2017 - Rule 96 of Central Goods and Services Tax Rules, 2017/Gujarat Goods and Services Tax Rules, 2017

This summary is for general information and is not legal advice. Read the full decision and the applicable law before relying on it.

The ruling in brief

Related rulings

Supreme Court21 Sept 2026

For revenue

Matrix Cellular (international) Services (P.) Ltd. v. Principal Commissioner, State Tax, Delhi

SLP dismissed against review petition of High Court holding that where assessee withdrew refund application after issuance of deficiency memo and later sought interest for that disputed period in review petition on ground of error apparent, as no error or mistake was found in earlier judgment denying interest for that period, review petition was not maintainable and not considered on merits

GSTAT Chandigarh24 Sept 2026

For assessee

Shruti Bansal v. Solitaire Pharmacia (P.) Ltd

Where exporter claimed refund of unutilised ITC for period based on invoices issued for export supplies under bond/LUT, turnover for refund was determined by invoice date within relevant period, not actual export date, so denial on ground of subsequent export was unwarranted when export stood established and invoices fell in period, making refund allowable. GST: Where exporter claimed refund of unutilised ITC for export without payment of tax and department alleged minor inclusion of ineligible credits in Net ITC computation under rule 89(4), such ineligible ITC did not materially impact maximum refund, which remained higher than amount sanctioned, so refund grant required no disturbance and departmental appeal was dismissed

GSTAT Ranchi23 Sept 2026

For assessee

Principal Commissioner of CGST & CX v. Shivam Iron & Steel Co. Ltd

Reversal of ITC (Cess) relating to earlier periods could not be deducted from Net ITC for current refund period under Rule 89(4); “input tax credit availed” would refer to credit actually availed during current period, and para 43(c) of Circular No. 125/44/2019-GST could not override statute, hence, refund was properly computed

MAC Industry v. Union of India

The ruling in brief

Provisions considered

MAC Industry v. Union of India

The ruling in brief

Provisions considered

Read the full analysis

Matrix Cellular (international) Services (P.) Ltd. v. Principal Commissioner, State Tax, Delhi

Shruti Bansal v. Solitaire Pharmacia (P.) Ltd

Principal Commissioner of CGST & CX v. Shivam Iron & Steel Co. Ltd

Read the full analysis