Rule 96(10) is Ultra Vires. Kerala High in SANCE LABORATORIES PRIVATE LIMITED Vs UNION OF INDIA

The Rule 96(10) of the CGST Rules, as inserted by notification No.53/2018-CT dated 09-10-2018 w.e.f. 23-10-2017, as ultra vires the provisions of Section 16 of the IGST Act and unenforceable on account of being manifestly arbitrary - No proceedings shall be taken to recover any IGST that has been refunded to the petitioners by applying the provisions of Rule 96(10) of the CGST Rules for the period between 23-10-2017 and 08-10-2024 .