ORDER

A.C. Rao, J.

1. As common question of law arise in both these petition and as in both these petitions, the petitioners have challenged the provisions of Central Goods and Service Tax Act, 2017 and Notification and Circular issued thereunder, by which the inverted tax structure refund of excess duty is not granted, the same are heard, decided and disposed of by this common order.

2. By way of Special Civil Application No. 16213 of 2018, petitioner -Shabnam Petrofils Pvt. Ltd. has prayed for the following main reliefs:-

"16(B). Your Lordships may be pleased to issue writ of mandamus or any other writ in the nature of mandamus or any other appropriate writ quashing and setting aside the Notification dated 26.07.2018 being No. 20/2018 : and Circular dated 24.08.2018 being Circular No. 56/30/2018-GST : as contrary to Section 54(3) of the Central Goods and Service Tax Act, 2017 as well as notification dated 28.06.2017 being Notification No. 5/2017-Central Tax [Rate] : and declare the said Notification and Circular as violative of Articles 14 and 19(1)(g) of the Constitution of India."

2.1. By way of Special Civil Application No. 20626 of 2018, petitioners -federation of Gujarat Weavers Welfare Association and others have prayed for the following main reliefs:-

"9(a); YOUR LORDSHIPS may be pleased to issue a Writ of Certiorari or a writ in the nature of Certiorari or any other writ, order or direction under Article 226 of the Constitution of India calling for the records pertaining to the Petitioners case and after going into the validity and legality thereof to quash and set aside:

(i) proviso (ii) of the opening paragraph of the Notification No. 05/2017-C.T. (Rate) : dated 28.06.2017 inserted vide Notification No. 20/2018-C.T. (Rate) : dated 26.07.2018 issued by the Respondent No. 1;

(ii) proviso (ii) of the opening paragraph of the Notification No. 05/2017-S.T. (Rate) dated 30.06.2017 inserted vide Notification No. 20/2018-S.T. (Rate) dated 26.07.2018 issued by the Respondent No. 2; and

(iii) proviso (ii) of the opening paragraph of the Notification No. 05/2017-I.T. (Rate) : dated 28.06.2017 inserted vide Notification No. 21/2018-I.T. (Rate) dated 26.07.2018 issued by the Respondent No. 1; and

(b). YOUR LORDSHIPS may be pleased to issue a Writ of Certiorari or a writ in the nature of Certiorari or any other writ, order or direction under Article 226 of the Constitution of India calling for the records pertaining to the Petitioners case and after going into the validity and legality thereof to quash and set aside the Circular No. 56/30/2018-GST : dated 24.08.2018 issued by the Respondent No. 4;

(c). YOUR LORDSHIPS may be pleased to issue writ of Mandamus or a writ in the nature of Mandamus or any other appropriate writ, or order or direction under Article 226 of the Constitution of India, ordering and directing the Respondents, their subordinate servants and agents to forthwith withdraw and cancel:

(i) proviso (ii) of the opening paragraph of the Notification No. 05/2017-C.T. (Rate) : dated 28.06.2017 inserted vide Notification No. 20/2018-C.T. (Rate) : dated 26.07.2018 issued by the Respondent No. 1;

(ii) proviso (ii) of the opening paragraph of the Notification No. 05/2017-S.T. (Rate) dated 30.06.2017 inserted vide Notification No. 20/2018-S.T. (Rate) dated 26.07.2018 issued by the Respondent No. 2; and

(iii) proviso (ii) of the opening paragraph of the Notification No. 05/2017-I.T. (Rate) : dated 28.06.2017 inserted vide Notification No. 21/2018-I.T. (Rate) : dated 26.07.2018 issued by the Respondent No. 1; and

(d). YOUR LORDSHIPS may be pleased to issue writ of Mandamus or a writ in the nature of Mandamus or any other appropriate writ, order or direction under Article 226 of the Constitution of India, ordering and directing the Respondents, their subordinate servants and agents to forthwith withdraw and cancel the ' Circular No.