JUDGMENT :

(Bhargav D. Karia, J.)

1. Heard learned Senior Advocate Mr. Mihir Joshi with learned advocate Mr. Kuntal Parikh for the petitioners and learned A.G.P. Mr. Raj Tanna for the respondents.

2. Rule returnable forthwith. Learned A.G.P. Mr. Raj Tanna waives service of notice of Rule for the respondents. Having regard to the controversy in narrow compass with the consent of the learned advocates, the matter was taken for final hearing.

3. The petitioners have challenged the order dated 17th February 2021 in the proceedings before the Advance Ruling Authority in Appeal No.GUJ/GAAR/Appeal/2021/05 only to the extent to the limited findings of the respondent No.2 – Appellate Authority for Advance Ruling Gujarat, whereby it is held that the Notified Area Authority, Vapi is neither a “local authority” nor “governmental authority” and therefore, the petitioners are not entitled to exemption under the Notification No.12/2017-Central Tax (Rate) dated 28th June 2017 and the Notification No.12/2017-State Tax (Rate) dated 30th June 2017.

4. The petitioner No.1 is engaged in the business of Solid Waste Management and recycling services. The Notified Area Authority, Vapi floated a Tender invitin