Ramachandran Nair, J.

Both the Writ Appeal and Writ Petition filed by the same company pertain to sales tax liability for a bridge constructed under the Build, Operate and Transfer (BOT) scheme. The bridge is across the backwaters connecting Willingdon Island to the main land. The first contract was between Greater Cochin Development Authority and the appellant/petitioner herein. However, later a subsidiary company of the appellant/petitioner by name Cochin Bridge Infrastructure Co. Ltd., CBICL, was brought in and a tripartite agreement was executed among GCDA, petitioner and CBICL providing for construction of the bridge, operation of the bridge by CBICL and transfer the same after 19 years of use by them. CBICL thereafter awarded the construction contract to the petitioner for Rs. 2,215 lakhs. Construction of the bridge commenced in the year 1999-2000, and according to the petitioner, petitioner filed compounding application for payment of tax under Section 7(7) of the Kerala General Sales Tax Act, 1963, hereinafter called KGST Act. However, the application was not processed in time and no orders were issued. Even though orders on compounding application was issued in