High Court of Gujarat25 August 2026

Maldeep Catalysta (P.) Ltd. v. Union of India

For assessee

R/SPECIAL CIVIL APPLICATION NO. 171 OF 2026

The ruling in brief

Where restriction under Rule 96(10) on IGST refund for exports was invoked after its omission without any saving or sunset clause, omission indicated legislative intent to end restriction for pending proceedings, so restriction could not apply and assessee was entitled to refund, rendering impugned communication unsustainable

Provisions considered

CGST Rules R.96

Rule 96, read with rule 96(10), 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 assessee

Union of India v. Aculife Healthcare (P.) Ltd

SLP was filed against impugned order of High Court holding that where refund granted to assessee on export of goods was sought to be demanded under Rule 96(10), since Notification No. 20-2024, dated 8-10-2024 was issued during pendency of appeal filed by assessee against such demand, whereby Rule 96(10) was omitted, proceedings of order in original as well as order passed by appellate authority were to be set aside; instant court held issues were squarely covered by Goodluck India Ltd. v. Union of India & Ors. and dismissed SLP

Karnataka High Court15 Sept 2026

For assessee

Union of India v. ABB Global Industries and Services (P.) Ltd

Where assessee's refund of tax paid on export of services was rejected under Rule 96, since Rule 96(10) had been omitted without any saving or sunset clause, ongoing restriction could not be maintained and refund could not be denied in view of Supreme Court's decision that proceedings under an omitted rule cannot continue in absence of any saving provision

Gujarat High Court3 Sept 2026

For assessee

MAC Industry v. Union of India

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

Maldeep Catalysta (P.) Ltd. v. Union of India

The ruling in brief

Provisions considered

Maldeep Catalysta (P.) Ltd. v. Union of India

The ruling in brief

Provisions considered

Read the full analysis

Union of India v. Aculife Healthcare (P.) Ltd

Union of India v. ABB Global Industries and Services (P.) Ltd

MAC Industry v. Union of India

Read the full analysis