Rule. Respondents waives service. By consent Rule made returnable forthwith.

2. By this petition under Article 226 of the Constitution of India, the petitioner is impugning the demand notice dated 3rd March 2011 under which a demand of Rs.86,32,75,991/- has been raised. It is seeking a direction to the respondents to calculate the amount of 25% rebate due to it on the basis of the order dated 21st January 1999 and 13th February 2001 passed by this Court and the Supreme Court and refund the balance amount due to it. Prayer clause (c) of the petition reads as under:

“(c) to direct the respondent to reimburse the balance 25% rebate arrears amounting to a sum of Rs.4 crore as the principal amount and Rs.149 crore as the interest @ 24% per annum thereon i.e a total sum of Rs.153 crore approximately as on 1st October 2010 as per the guidelines laid down in the judgment of this Hon’ble Court dated 21.01.1999;”

3. The facts necessary to appreciate the challenge are that the petitioner is a company registered under the Companies Act, 1956 and carrying on manufacture of speciality Steel for Automobile Sector, Defence, Railways etc. It claims to be a Sick Industrial Unit. The peti