JUDGMENT

Rajiv Shakdher, J. - In this writ petition, the following reliefs have been claimed by the petitioners:

"a) Declare that Paragraph 11(d) read with 12A(a)(ii) of the Notes and Conditions of the Notification No. 131/2016-Cus. (N.T.), dated 31.10.2016 (Annexure P-2) [as amended by Notification No. 59/2017-Cus. (NT) dated 29.06.2017 (Annexure P-3) and Notification No. 73/2017-Cus. (NT) dated 26.07.2017 (Annexure P- 4)] are (i) ultra vires Section 16 of the IGST Act, 2017 read with Section 54 of CGST Act, 2017 and Rule 96 of CGST Rules, 2017, & (ii) unconstitutional and violative of Article 14, 19 and 21 of the Constitution of India & Quash the same;

b) Declare that Circular No. 37/2018-CUSTOMS dated 09.10.2018 (Annexure P-7) is (i) ultra vires Section 16 of the IGST Act, 2017 read with Section 54 of CGST Act, 2017 and Rule 96 of CGST Rules, 2017, and (ii) unconstitutional and violative of Article 14, 19 and 21 of the Constitution of India & Quash the same;

c) As a consequence of the above, Direct Respondent Authorities to grant refund of IGST paid on goods exported by the Petitioners during the Transitional Period".

2. Upon notice being issued, a counter-affidavit has been filed b