JUDGMENT :

MS. B.S. BHANUMATHI, J.

Heard Mr. S. Suribabu, learned counsel for the petitioner and Mr. Y. N. Vivekananda, learned Government Pleader, Commercial Tax, for the respondents.

2. The petitioner has moved the Court, for the following relief:

“…to issue a Writ or order or direction particularly one in the nature of the Writ of mandamus setting aside the impugned assessment order passed by the first respondent in Form GST DRC – 07 dated 01.09.2021 passed for the tax period July, 2017 to November, 2019 vide AAO No.ZH370921OD51289 in seeking to levy tax on Transferable Development Rights pursuant to the Joint Development Agreement-cum-General Power of Attorney entered into by the petitioner with the land owners on 30.10.2017 along with interest and penalty as illegal, arbitrary, without Authorization, against Principles of Natural Justice, contrary to the provisions of the CGST Act, 2017 and APGST Act, 2017, contrary to the Notification and Circular issued by the Union of India, unsustainable in law, passed without application of mind, not considering any of the objections filed by the petitioner and is without jurisdiction; and …….”

3. Learned counsel for the petitioner submitted