JUDGMENT

1. The petitioner is a registered dealer under the provisions of the West Bengal Value added Tax act, 2003 (the 'act'), engaged in the business as reseller of furniture. The petitioner challenges the order passed by the learned West Bengal Taxation Tribunal (the 'Tribunal') in R.N. No. 1155 of 2018 dated 20.02.2020 and R.N. No. 1034 of 2019 dated 20.12.2017. The challenge to the order of the learned Tribunal is not in its entirety but only with regard to the finding of the Tribunal that the contract which was entered into by the petitioner with Tata Consultancy Services Ltd. (TCS) to be a works contract and liable for tax under the provisions of the act. The petitioner also challenges the order of the learned Tribunal dated 20.02.2020 to the extent it is held that the works contract is zero rated under Section 21 a of the act. The learned Tribunal had interpreted the nature of contract entered by the petitioner with TCS to be two separate contracts and should be considered according to the nature and purpose for which they have been entered into. This finding of the learned Tribunal has not been challenged by the petitioner. The petitioner also challenges the order passed b