The Hon’ble Karnataka High Court in M/s. Tonbo Imaging India Pvt Ltd v. Union of India [W.P.C No. 13185 of 2020] (T-RES) dated February 16, 2023] has held that Rule 89 (4)(c) of the Central Goods and Service Tax Rules, 2017 (“the CGST Rules”) which restricts the exports made without payment of tax (i.e., under Letter of Undertaking model (“LUT Model”)) to 1.5 times value of like goods supplied domestically is unconstitutional and ultra vires of the provisions of the GST law.