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of The HC directed the refund of IGST paid under Section 16(3) of IGST Act read with Section 54 of CGST Act and Rule 96 of CGST Rules for zero-rated supply. The court determined that departmental circulars cannot override Rule 96, relying on precedent established in Amit Cotton Industries (Gujarat HC). The court ordered the respondent to refund Rs. 12,72,827 with applicable interest to the petitioner within eight weeks from receipt of the order. The petition was allowed, confirming that administrative circulars cannot supersede statutory rules governing IGST refund procedures for zero-rated supplies.
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