V. RAMASUBRAMANIAN, J.

The petitioner has come up with the above writ petition challenging an order of assessment passed by the 3rd respondent herein under the Andhra Pradesh Value Added Tax Act, 2005 for various tax periods in the years 2012-13 and 2013-14.

2. Heard Mr. S. Ravi, learned Senior Counsel for the petitioner, learned Advocate General for the State of Andhra Pradesh appearing for the respondents 2 and 3, and Mr. B. Narayana Reddy, learned Assistant Solicitor General of India for the respondents 1 and 4.

3. The petitioner is engaged in the business of carrying on offshore drilling operations for petroleum exploration and production company. The petitioner was awarded various contracts by the contractor of the Oil and Natural Gas Corporation Limited (ONGC), for carrying out offshore drilling activities. According to the petitioner, these contracts were entered into at Mumbai on various dates.

4. For the purpose of carrying out the due execution of the contracts, the petitioner imported various drilling rigs. These rigs were mobilised both at the east-coast and west-coast. It is claimed by the petitioner that these rigs were used exclusively in the western coast for dri