GST refund on account of accumulated ITC for exports without payment of tax

CBIC circular 23.03.2020 requires exporters to compare export prices with domestic sales price of same product by similar sellers.

Any resolution for below issues ??

1. In case of CIF contract, insurance and freight component is apportioned to various product categories based on weight/value etc. However no such huge expenses incur in case of domestic sales

2. The export prices could differ in a big way if the export is done through air instead of sea.

3. It is possible that the goods exported are not sold in domestic market at all by same seller as well any other seller.

4. Its difficult to find similar placed sellers as there could be differences like volume,capital,workforce.

5. Export and domestic product and pricing database comes at very high costs.

What are the exporters practically submitting to the GST officials for sanction of their refund?