JUDGMENT :

SONIA GOKANI, J.

1. Issues involved are identical and therefore, both the petitions are being decided by a common judgment and order where the relevant facts for adjudication are essentially drawn from the Special Civil Application No.8057 of 2020.

2. By way of the present petition, the petitioner seeks following relief :

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(A) Your Lordships may be pleased to issue a writ of certiorari, or a writ in the nature of certiorari or any other appropriate, writ order or direction quashing order of reassessment of bills of entry No.5407944 and 5407946 ‘Annexure B (Colly);

(B) Your Lordships may be pleased to issue a writ of mandamus or a writ in the nature of mandamus or any other appropriate writ, order or direction directing the respondent No.3, his servants and agents to return/refund the differential amount of duty paid by the petitioner company being Rs.72,15,893/- regarding bill of entry No.5407944 and Rs.72,15,611/- regarding bill of entry No.5407946;

(C) Your Lordships may be pleased to issue a writ of certiorari or a writ in the nature of certiorari or any other writ, order or direction quashing order in appeal No.KDLCUSTM- 0000-APP-07 to 071-18-19 dated 21.1.2019 (Annexure