Petitioner Challenges ITC Refund Denial Under Article 14, 300A, and Section 54 of CGST Act; Cites Conflicting Circular.

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....Refund of accumulated Input Tax Credit - input and output supplies are same - Violation of Article 14, and Article 300A of the Constitution of India and Section 54 of the Central Goods and Services Tax Act, 2017 or not - the circular dated 31.03.2020, being a subordinate legislation, is repugnant and conflicting to the parent legislation i.e. Section 54(3)(ii) of the CGST Act and hence, the same cannot be applied to oust the legitimate claim for accumulated ITC refund filed by the petitioner - HC....