GST – Sec. 54 – Circular No. 135/05/2020 – GST, dated 31-03-2020 which stipulates that refund under inverted duty structure in terms of section 54(3)(ii) would not be available where input and output supplies are same in repugnant and conflicting to parent legislation, i.e., Sec. 54(3)(ii).

Baks Hughes Asia Pacific Ltd. v. UOI, [2022] 140 taxmann.com 326 (Rajasthan).