Omission of Rule 96(10) of the CGST Rules without a saving clause nullifies all pending proceedings

The Hon’ble Supreme Court in M/s. Goodluck India Limited & Anr. v. Union of India & Ors. [Special Leave Petition (C) No. 24550 of 2025 along with connected appeals dated August 06, 2026] dismissed the appeals filed by the Revenue and declined to interfere with the judgment of the Hon’ble Gujarat High Court in Addwrap Packaging Pvt. Ltd. & Anr. v. Union of India & Ors. [R/Special Civil Application No. 22519 of 2019 dated June 13, 2025], thereby affirming that the omission of Rule 96(10) of the Central Goods and Services Tax Rules, 2017 (“the CGST Rules”) vide Notification No. 20/2024-Central Tax dated October 08, 2024, without any saving clause, applies squarely to all proceedings pending on the date of omission and such pending proceedings cannot be continued thereafter.

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