$~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 1. 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 authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 16/09/2026 at 12:40:52 omission of Rule 96(10) without any saving clause, proceedings pending under the said Rule could not be continued, and the benefit of the omission would inure to assessees in all such pending proceedings. 3. Learned counsel representing the parties do not dispute that the proceedings against the Petitioner under Rule 96(10) were pending on 08.10.2024 and are, therefore, covered by the aforesaid judgment. 4. Accordingly, the Order-in-Original dated 31.01.2025, insofar as it confirms the demand of ₹21,09,79,285/- under Rule 96(10) of the CGST Rules, together with consequential interest and penalty, is set aside. The proceedings arising from the Demand-cum-Show Cause Notice dated 31.07.2024, to the aforesaid extent, shall stand closed. 5. The Order-in-Original dated 31.01.2025 also confirms a separate demand arising from Notifications Nos. 40/2017 and 41/2017 dated 23.10.2017. 6. Since the said demand is not founded upon Rule 96(10) of the CGST Rules, this Court has not examined the same on merits. The Petitioner shall be at liberty to challenge the said part of the Order-in- Original by availing the statutory remedy of appeal under Section 107 of the CGST Act. If such appeal is filed within four weeks from today, along with the requisite pre-deposit, the same shall not be dismissed on the ground of limitation and shall be adjudicated on merits. 7. The present Writ Petition, along with the pending applications, is disposed of in the aforesaid terms. ANIL KSHETARPAL, J. SHAIL JAIN, J. SEPTEMBER 7, 2026 jai/ad This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 16/09/2026 at 12:40:52