Ridley Life Science PVT. LTD vs. Union Of INDIA & Ors.

W.P.(C)/15839/2024HC DelhiGSTCNR DLHC01079643202407 September 2026Bench: HON'BLE MR. JUSTICE SHAIL JAIN,HON'BLE MR. JUSTICE ANIL KSHETARPAL2 pages

For Petitioner: Mr.Adv.[appearance not given.]For Respondent: Mr. Syed Abdul Haseeb, CGSC with Mr. Muhammad Aamir Khan, Adv. for UOI. Mr. Anurag Ojha, SSC with Mr. Dipak Raj, Mr. Aryaman Singh Chouhan, Mr. Aditya Chaudhary, Advs. for R-2 to 4

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Held

The Court held that proceedings pending under an omitted rule without a saving clause cannot continue, and the benefit of omission accrues to assessees. The demand based on the omitted rule was set aside.

Facts

The petitioner challenged a demand-cum-show cause notice for recovery of IGST refund due to alleged violation of Rule 96(10) of CGST Rules. The proceedings continued even after Rule 96(10) was omitted.

Key Issues

Whether proceedings under an omitted rule can continue and if the omission benefits pending cases. Whether a separate demand not based on the omitted rule can be challenged via appeal.

Sections Cited

Rule 96(10), Section 107

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Cause title — parties, addresses and appearances

$~25 * IN THE HIGH COURT OF DELHI AT NEW DELHI # CNR No. DLHC010796432024 + W.P.(C) 15839/2024, CM APPL. 9932/2025 and CM APPL. 23551/2025 RIDLEY LIFE SCIENCE PVT. LTD .....Petitioner Through: Mr.Adv.[appearance not given.] versus UNION OF INDIA & ORS. .....Respondents Through: Mr. Syed Abdul Haseeb, CGSC with Mr. Muhammad Aamir Khan, Adv. for UOI. Mr. Anurag Ojha, SSC with Mr. Dipak Raj, Mr. Aryaman Singh Chouhan, Mr. Aditya Chaudhary, Advs. for R-2 to 4. CORAM: HON'BLE MR. JUSTICE ANIL KSHETARPAL HON'BLE MS. JUSTICE SHAIL JAIN

O R D E R % 07.09.2026

Through the present Writ Petition, the Petitioner had challenged, inter alia, the Demand-cum-Show Cause Notice dated 31.07.2024, whereby recovery of IGST refund amounting to ₹21,09,79,285/- was proposed on the ground of violation of Rule 96(10) of the Central Goods and Services Tax Rules, 2017. During pendency of the present Petition, the proceedings culminated in the Order-in-Original dated 31.01.2025. 2. Rule 96(10) of the CGST Rules stood omitted with effect from 08.10.2024. The Supreme Court in M/s Goodluck India Limited & Anr. v. Union of India & Ors.; 2026 INSC 821, has held that, upon This is a digitally signed order. The a

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