Ramesh Ranganathan, J.

While W.P.Nos.7561, 8285, 8287, 8288, 8317 and 8448 of 2014 are filed questioning the order of the revisional authority-Deputy Commissioner (CT) dated 31.01.2014, under Section 32(2) of the AP VAT Act, 2005, revising the assessment orders, for the assessment years 2011-12, 2010-11, 2009-10, 2006-07, 2007-08 and 2008-09 respectively, the order under challenge in W.P.No.19501 of 2014 is the assessment order passed by the assessing authority dated 31.05.2014 levying tax on the petitioner for Rs.9,62,91,291/- for the assessment year 2012-13.

The petitioner, a company incorporated under the Companies Act, executes works contracts and is an assessee on the rolls of the Assistant Commissioner (CT), LTU, Visakhapatnam. Pursuant to the agreement entered into between the Government of Andhra Pradesh (GoAP for short) and M/s.Krishnapatnam Port Company Limited (KPCL for short) on 17.09.2014, for building a deep water sea port at Krishnapatnam on build, operate, share, and transfer basis with a concession period of 50 years, KPCL awarded the works contract, for construction of the port, to the petitioner (hereinafter referred to as NECL); under Clause 3.16, the GoAP un