JUDGMENT :

T.R.Ravi, J.

Sri Mithun Davis, the owner of Edassery Kayal Resorts, leased out his property to M/s. Prestige Holiday Resorts Pvt.Ltd (hereinafter referred to as the lessee company), who in turn entered into a management agreement with M/s.Royal Goan Beach Resorts LLP, the petitioner herein, for running the hotel. The petitioner entered into an agreement with M/s. Regal Vacation Concepts Private Ltd(hereinafter referred to as Time share company), who is doing business of Timeshare, agreeing to provide accommodation to the guests who are booked through the time share company, at the rate of Rs.1,600/-per night, provided the company makes a minimum booking of at least 500 nights in a year. The lessee company, the petitioner and the Time share company are all sister concerns. The business module, though it looks very impressive and can be a study material for a business management student on its viability; we are not called upon to research into such intricacies. We are only expected to answer a challenge to an order passed by the assessing authority, confirmed in appeal before the Tribunal, whereby the petitioner has been assessed to luxury tax.

2. The assessment relates to th