JUDGMENT :

DEEPAK ROSHAN, J.

1. The instant writ application has been preferred by the petitioner praying therein for the following reliefs:

(i) For issuance of appropriate writ/order/direction, directing the Respondents to produce before this Hon’ble Court the refund rejection order being RFD-06 No. 91 dated 18.10.2019 allegedly passed by Respondent No. 3 and to consequentially quash the same, wherein the application for refund filed by Petitioner vide Application Reference Number (ARN) AA200318232092U dated 04.03.2019 for the period July, 2017 to March, 2018 on account of ‘refund of ITC on export of goods and services without payment of tax’ has been rejected.

(ii) For issuance of further writ/order/direction including Writ of Mandamus, directing Respondent-authorities, particularly Respondent No. 3 to immediately refund an amount of Rs. 2,90,86,294/-for the period 2017-18 as admittedly the Petitioner is entitled for refund of the said amount in terms of the provisions of Section 54(3) of the Central Goods and Services Tax Act, 2017.

(iii) For issuance of further writ/order/direction including Writ of Mandamus, directing Respondents to pay statutory interest on the refundable amount of Rs. 2,90,86,294/-@ 6% with effect from expiry of 60 days from the date of receipt of application for refund, till the date of payment of the refundable amount.

2. The facts as it emerges for the averments made in the respective affidavits it appears that the Petitioner is a government company and the instant writ application pertains to its Bokaro Steel Plant, which is primarily engaged in the business of manufacture of iron and steel and is duly registered under the provisions of the Goods and Services Tax Act, 2017 bearing GSTIN No. 20AAACS7062FAZJ.

3. For the purpose of manufacture of iron and steel, Petitioner requires various raw materials including ‘coal’ which is subjected to levy of compensation cess under ‘The Goods and Services Tax (Compensation to States) Act, 2017. In terms of Section 11 of the aforesaid Act, compensation cess payable on Inputs is permitted to be adjusted only against tax liability of compensation cess, and, unutilized compensation cess is not adjustable against the liability towards CGST, SGST and IGST. However, in case of export, excess ITC available towards compensation cess at the hands of the assesse can be claimed as refund in terms of Section 16 read with Section 54 of the CGST Act.

4. Accordingly, Petitioner applied for refund of unutilized ITC for the period 2017-18 on account of refund of ‘ITC on export of goods and services’ without payment of tax for an amount of Rs. 2,90,86,294/-. Said application for refund was filed in Form GST-RFD 01A dated 04.03.2019 bearing ARN No. AA200318232092U.

5. Subsequent upon filing of such application, the jurisdictional assessing officer of the Petitioner i.e. Deputy Commissioner of State Tax, Bokaro Circle, Bokaro (Respondent No. 3), vide Information No. 1245 dated 12.06.2019, asked certain clarifications from the Petitioner, and, the Petitioner submitted such clarifications with Respondent No. 3.

6. The Petitioner, thereafter, received an e-mail dated 27th October, 2019 mentioning, inter-alia, that ‘Order details against RFD 06 have been submitted by the Tax Official for ARN AA200318232092U dated 22.10.2019’.

7. Subsequently, Petitioner checked status of its Refund Application online and in the online portal, it was clearly reflecting that refund of the Petitioner has been sanctioned for an amount of Rs. 2,90,86,294/-and payment advice in RFD05 was yet to be issued by the jurisdictional officer. Although Petitioner received such communication in its online portal as well as e-mail, payment advice in RFD05 was not issued by the jurisdictional officer and, hence, Petitioner’s representative met Respondent No. 3 for issuance of payment advice, but it was informed by Respondent No. 3 that refund payment advice could not be issued due to some technical difficulties which Respondents a