GST Refund Denials Set Aside as Repealed Rules Cannot Survive Without Saving Clause

Mars Exports Vs Union of India & Anr. (Gujarat High Court) The present writ petitions were disposed of in terms of an earlier judgment dated 20.11.2025 passed in a group of matters, which addressed the effect of Notification No. 20/2024 dated 8th October 2024. By this Notification, Rule 96(10) of the CGST Rules was omitted prospectively without any saving clause. In the earlier judgment, the Court had held that the omission of Rule 96(10) would apply not only prospectively but also to all pending proceedings and cases where final adjudication had not taken place as on 8th October 2024. Acc...