Akil Kureshi, J.

The petitions arise in similar background. For convenience, we may record facts from Special Civil Application No.18433/2017.

2. Petitioner no.1 is a company registered under the Companies Act and would here-in-after be referred to as "the petitioner company". Petitioner no.2 is the Director of the company. Petitioner company is engaged in trading of specialized industrial bearings of various types. The petitioner also imports certain goods. Under the old regime, i.e. before introduction of Goods and Service Tax, the excise duty on local goods or the countervailing duty paid on imports was not to be borne by the petitioners. The credit could be utilised for payment of tax. According to the petitioners, the company has to maintain sufficient stock of different kinds of such bearings, many of which items may not be immediately sold. The petitioners would therefore, have longer cycle of such goods remaining with the petitioners after purchasing from the manufacturer before they are sold.

3. Before introduction of Goods and Service Tax regime ("GST" for short), the petitioners' transactions of purchase and sale of goods were covered under the Central Excise Act 19