ORDER :

Leave granted.

2. We have heard learned counsel for the parties.

3. The present appeal emanates from the final judgment and order passed by the learned Single Judge of the High Court at Calcutta (hereinafter referred to as the “High Court”) in Writ Petition bearing W.P.A. No.17452 of 2019 dated 2nd August, 2022 (hereinafter referred to as the “Impugned Judgment”), by which the said petition was dismissed.

BRIEF FACTS:

4. The appellant, being a company, carries on the business of horizontal directional drilling using trenchless methodology for underground utilities -oil/gas, telecom and power. The appellant functions as a contractor and is duly registered under the Central Goods and Services Act, 2017 (hereinafter referred to as the “CGST Act”) and the West Bengal Goods and Services Act, 2017 (hereinafter referred to as the “WBGST Act”). For many years, the appellant executed work contracts of the Gas Authority of India Limited (hereinafter referred to as “GAIL”), including work in the State of West Bengal for Dobhi-Durgapur Gas Pipeline Section. Prior to this, the appellant had executed work for GAIL in the State of Uttar Pradesh in Auraiya district.

5. Insofar as the execution