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The HC dismissed the petition as prematurely maintainable, holding that the Trade Circular dated 13 August 2024 sufficiently protects the Petitioner and affords an efficacious alternative remedy. The Petitioner, having filed this petition on 17 April 2025 within the period prescribed by the Circular, must submit the Annexure-1 form within four weeks of upload of this order to avail the Circular's benefits. The court directed that once the GST Tribunal is constituted and functional, the Petitioner may pursue an appeal against the impugned order dated 24 February 2025; failure on appeal will not foreclose the Petitioner's liberty to subsequently challenge the constitutional validity of Section 16(2)(c). Petition disposed.