JUDGMENT :

J.B. PARDIWALA, J.

1. By this writ application under Article 226 of the Constitution of India, the writ applicant-a Public Limited Company has prayed for the following reliefs:

"A. This Hon'ble Court may be pleased to issue a writ of mandamus or a writ in nature of mandamus or any other appropriate to forthwith grant refund of tax amount of Rs. 1,87,69,739 under the CST Act collected from the petitioner and deposited by the seller along with appropriate interest on such refund amount;

B. Pending notice, admission and final hearing of this petition, this Hon'ble Court may be pleased to direct the learned respondents to forthwith grant refund of tax amount of Rs. 1,87,739 under the CST Act collected from the petitioner and deposited by the seller along with appropriate interest on such refund amount;

C. Ex parte ad interim relief in terms of prayer B may kindly be granted;

D. Such further relief(s) as deemed fit in the facts and circumstances of the case may kindly be granted in the interest of justice for which act of kindness your petitioner shall forever pray."

2. We have heard Mr. Uchit Sheth, the learned counsel appearing for the writ applicant and Mr. Utkarsh Sharma, the l