JUDGMENT :

S.V.Bhatti, J.

We have heard the learned Special Government Pleader, Mr Mohammad Rafiq and the learned Senior Counsel, Mr Abraham Joseph Markos, for the appellants and the respondents, respectively.

2. The respondents in W.P.(C) No.16431/2013 are the appellants, and the respondents herein are the petitioners in W.P.(C) No.16431/2013. The parties are referred to as arrayed in the Writ Petition.

Averments in W.P.(C) No.16431/2013

3. The 1st petitioner/Company is engaged in the manufacture and sale of electrical control systems. The manufacturing unit of the 1st petitioner is located within the Cochin Special Economic Zone (CSEZ), Kakkanad. The 1st petitioner, because of its location in a Special Economic Zone (SEZ), claims statutory/other benefits given to units located in an SEZ. As part of its turnover, the 1st petitioner claims to have two portfolios: viz. exports outside the country and deemed exports in the permitted Domestic Tariff Area (for short ‘DTA’). The petitioner, for availing the benefits, is subjected to the condition of obtaining positive foreign exchange earnings. In December 2002, the 1st petitioner commenced its operations from CSEZ.

3.1 The 1st petitioner in