-Section 168-Since the impugned circular (Circular No. 80/54/2018-GST dated 31-12-2018) was already aside by a coordinate Bench of the Court, therefore, petitioners’ grievance with regard to the said circular does not survive

-Section 67-Since reason for carrying out search were provided to Joint Commissioner subsequently which he signed on the date following the search, thus, the search carried out was illegal as authorisation was vitiated

-Section 54- Refund under inverted duty Structure does not contemplate comparing rate of tax on the principal input with that on principal output and Circular No.135/05/2020 has no application where ITC, has accumulated on account of rate of taxes on certain inputs being higher than tax chargeable on output, notwithstanding that one of the main input and output is chargeable at the same rate of tax