ORDER :

C.Praveen Kumar, J.

Heard Sri Mahesh Rai Chanda Nai, learned counsel representing Sri G. Arun Showri, learned counsel for the petitioner, Sri Y.N. Vivekananda, learned Government Pleader for Commercial Taxes appearing for respondents 2, 5 & 6, and Sri Suresh Kumar Routhu, learned standing counsel appearing for respondents 3 & 4. Perused the record.

2. The present writ petition came to be filed under Article 226 of the Constitution of India seeking issuance of a Writ of Mandamus directing the respondents 5 & 6 to declare the goods manufactured by the petitioner as classifiable under Chapter Heading 0804 50 40 and exempt from GST in terms of entry 51 of Notification No.2/2017-CT(Rate) dated 28.06.2017, apart from other reliefs.

3. As seen from the record, by an order dated 27.07.2022, this Court, taking into consideration the submissions made across the Bar, directed the respondents herein not to take any coercive steps for recovery of GST @ 18% as contemplated by them in respect of past transactions and insofar as future transactions are concerned, in view of the dispute as to whether ‘mangoes’ mentioned in the notification include ‘mango pulp’, directed that petitioner shall pa