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of Refund claim - provision of time of supply of goods is applicable u/s 12 of CGST Act, 2017 for export of goods during the period of October to December 2017 or not - applicability of Section 16 of the IGST Act, GST in India on exports - The observation made by the Commissioner (Appeal) in respect of the provisions of Section 173 of CGST, are in respect of the repeal of notification 41/2012-ST without even referring to the Section1 74 (2) ibid, cannot impact the rights accrued to the appellant prior to such repeal - AT
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