High Court of Karnataka15 September 2026

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

For assessee

WRIT APPEAL NO. 1524 OF 2026 (T-RES)

The ruling in brief

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

Provisions considered

Section 54 of Central Goods and Services Tax Act, 2017/Karnataka Goods and Services Tax Act, 2017 - Rule 96 of Central Goods and Services Tax Rules, 2017/Karnataka Goods and Services Tax Rules, 2017 - Section 2(6) of Integrated Goods and Services Tax Act, 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

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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

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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

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

The ruling in brief

Provisions considered

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

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