ORDER :

Common Prayer : Writ Petitions filed under Article 226 of the Constitution of India, to issue a Writ of Certiorari, calling for the records on the files of the Respondent herein in TIN/33270460111/2011-12 and TIN/33270460111/2012-13, both dated 24.06.2019 quashing the same.

The petitioner in both Writ Petitions is an Oil manufacturing Company, the Indian Oil Corporation Limited (in short ‘IOCL’), a Public Sector Undertaking engaged in the marketing of petroleum products and registered as a dealer under the provisions of the Tamil Nadu Value Added Tax Act, 2006 (in short ‘Act’).

2. In the course of its business, it had purchased Petroleum products, such as Motor Spirit (petrol), High Speed Diesel oil (HSD), furnace oil, Low Sulphur Heavy Stock (LSHS), Bitumen and Naphtha among others. Furnace oil is an input for power generation and is used by HT industrial users as fuel in gensets, to ensure and maintain continuous production.

3. The period in and around 2012 and 2013 saw the State of Tamil Nadu face power shortages and hence the demand for furnace oil at the instance of th