APHC010157472024 IN THE HIGH COURT OF ANDHRA PRADESH Bench Sr.No:-56 [3446]

AT AMARAVATI WRIT PETITION NO: 8499 & 8500 of 2024 W.P.No.8499 of 2024 ...Petitioner M/s. Krishna Sai Granites (india) Private Limited Vs.

The Joint Commissioner Of Central Taxes and Others ...Respondent(s)

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Advocate for Petitioner: ANIL KUMAR BEZAWADA Advocate(s) for Respondent(s): DEPUTY SOLICITOR GENERAL OF INDIA, Y N VIVEKANANDA CORAM : T HE CHIEF JUSTICE DHIRAJ SINGH THAKUR SRI JUSTICE R RAGHUNANDAN RAO DATE : 26th February 2026 P C :

As both these Writ Petitions raise an identical question of law, they are being disposed of, by way of this common order.

2. Heard Sri Anil Kumar Bezawada, learned counsel appearing for the petitioner and Sri Y.N. Vivekananda, learned counsel appearing for the respondents.

3. In W.P.No.8499 of 2024, the petitioner has approached this Court challenging the provisions of the Rule 96(10) of the Central Goods and Services Tax Rules, 2017 as well as the order in original, dated 21.12.2023, demanding recovery of refund of Rs.11,28,14,285/- sanctioned in relation to the exports for the period November, 2018 to September, 2022.

4. In W.P.No.8500 of 2024, the petitioner has app