JUDGMENT :

SONIA GOKANI, J.

1. The challenge here is to the order dated 11.06.2018 passed by the respondent No.3 granting refund of only principal amount of Rs.2,50,95,622/- (Rupees Two Crore Fifty Lakh Ninety-five Thousand Six Hundred Twenty Two only) without interest for the period spanning 2008 till the date to the petitioner under Section 54 of the Gujarat Sales Tax Act, 1969 (‘the GST Act’ hereinafter) alleging the same to be illegal and contrary to law.

2. This Court issued the notice to the respondent on 10.11.2022 by a following order:

“1. By way of the present petition under Article 226 of the Constitution of India, challenges the order passed by the respondents granting refund of only principal amount without interest, which according to the petitioner is contrary to law. The prayer sought for, is as follows:

“7. The petitioner, therefore, prays that this Hon’ble Court be pleased to issue a writ of mandamus or a writ in the nature of mandamus or a writ of certiorari or a writ in the nature of certiorari or any other appropriate writ, direction or order and be pleased to :

(a) command the Respondent/s to pay interest to the petitioner at 6% p.a. on Rs.1,73,27,355/- from 13.07.20