JUDGMENT :

JITENDRA JAIN, J.

1. Rule. Rule made returnable forthwith. Heard finally by consent of the parties.

2. This petition under Article 226 of the Constitution of India challenges review order dated 8th March 2021, passed by Respondent No. 3 under Section 25 of the Maharashtra Value Added Tax Act, 2002 (hereinafter referred as “MVAT Act”) and order dated 6th July 2021, passed by Respondent No. 3 on rectification application fled by the Petitioner, to rectify review order, under Section 24 of the MVAT Act for the financial year 2006-07.

3. Narrative of the relevant events:

(i) During the financial year 2006-07, the Petitioner executed two projects of electricity distribution line for Maharashtra State Electricity Distribution Company Limited (MSEDCL) and one works contract project for Gas Authority of India Limited (GAIL) for laying down the pipeline of gas between Dabhol to Panvel.

(ii) The Petitioner with respect to two contracts with MSEDCL claimed deduction from the contract price @ 25% as per Table prescribed in Rule 58 of the MVAT Rules for arriving at value of transfer of