JUDGMENT :

MANMOHAN, J.

1. Present writ petition has been filed seeking direction to the Respondent to refund to the petitioner the amount of Rs. 1,35,30,255/- being unutilized input tax credit for the months of October 2017 to July 2018 along with interest thereon.

2. Learned counsel for the Petitioner states that the present Petition arises on account of the failure of the Respondents to issue the refund due to the petitioner under the provisions of the Integrated Goods and Services Tax Act, 2017 and the Central Goods and Services Tax Act, 2017 [CGST Act] resulting on account of exports made by the Petitioner out of India which are termed as ‘Zero rated supplies’ in GST.

3. He states that the Petitioner is engaged in the business of purchase and exports of pharmaceutical products. He adds that the Petitioner was registered with the Trade and Taxes Department under VAT and on the enforcement of Goods and Services Tax Act, the Petitioner migrated to the said system of taxation as provided in Section 139 of the Central and Delhi Goods and Services Tax Act, 2017.

4. He emphasises that the exports done by the Petitioner out of India are zero rated and therefore, in terms of Section 16 of t