The Madras High Court, in a batch of writ petitions led by M/s. Global Calcium Pvt. Limited v. Union of India & Ors., dealt with challenges relating to Rule 96(10) of the CGST Rules, 2017. The petitions included challenges to the validity of the rule, show cause notices, orders-in-original and claims for refund.
Rule 96(10) was omitted by Notification No.20/2024 with effect from 8 October 2024. The petitioners relied upon the Gujarat High Court decision in Addwrap Packaging Private Limited v. Union of India and others, which held that the omission would benefit assessees whose proceedings were pending on the date of deletion.
The Madras High Court noted that the Gujarat High Court decision had been affirmed by the Supreme Court in Goodluck India Limited and another v. Union of India and others. Accordingly, the Court held that the deletion of Rule 96(10) would apply to all assessees in pending proceedings.
The Court further directed that cases involving show cause notices, orders-in-original and refund claims should be processed in accordance with the settled legal position. In W.P.No.12295 of 2022, the petitioner was permitted to apply for refund of the 10% amount deposited, subject to verification by the authorities and in accordance with law.
Case: M/s. Global Calcium Pvt. Limited v. Union of India & Ors.
Court: Madras High Court (Division Bench)
Case No.: W.P.Nos.33675 and 24377 of 2026 and batch cases
Date: 31 August 2026
Coram: Chief Justice Sushrut Arvind Dharmadhikari and Justice G. Arul Murugan
Result: Writ petitions disposed of; deletion of Rule 96(10) held applicable to pending proceedings.
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