Zero-rated export refund under GST cannot be denied by departmental circulars overriding the statutory refund mechanism.

Zero-rated export supplies under the GST scheme permit refund of IGST paid when the claim is made under Section 16(3) of the IGST Act read with Section 54 of the CGST Act and Rule 96 of the CGST Rules. The text states that a departmental circular cannot override the statutory refund mechanism or the governing rule. On that basis, refusal to process the refund was treated as unsustainable, and the refund with applicable interest was directed to be granted.

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Issues: Whether the petitioner was entitled to refund of IGST paid on zero-rated supplies under Section 16(3) of the Integrated Goods and Services Tax Act, 2017 read with Section 54 of the Central Goods and Services Tax Act, 2017 and Rule 96 of the Central Goods and Services Tax Rules, 2017, and whether the departmental circular could defeat that entitlement.

Analysis: The claim arose from zero-rated export supplies for which IGST had been paid. The cited statutory scheme permitted refund of the tax paid on such supplies, and the issue was treated as settled by existing precedent holding that a circular cannot override Rule 96. On that basis, the refusal to process the refund was unsustainable.

Conclusion: The petitioner was held entitled to refund of the IGST amount paid, along with applicable interest.

Final Conclusion: The writ petition succeeded and the revenue authority was directed to grant the refund with interest.

Ratio Decidendi: A departmental circular cannot override the refund mechanism provided under the GST statutory scheme for zero-rated supplies.

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