Hon’ble Ashwani Kumar Mishra, J.—Whether ‘Regasified Liquefied Natural Gas’ i.e. ‘RLNG’, sold to revisionist by Gas Authority of India Ltd. i.e. ‘GAIL’ is ‘Compressed Natural Gas (CNG)’, so as to oust it from the purview of taxing Entry 8(a) of Schedule IV of Uttar Pradesh Value Added Tax Act, 2008, (hereinafter referred to as ‘Act’) is the question for consideration in this revision. ‘RLNG’ is a Natural Gas and its name is derived with its flow from M/s Ras Laffan Liquefied Natural Gas Company Limited at Doha, Qatar, the source company from which it is procured by ‘GAIL’.

2. Revisionist is a public limited company incorporated under The Companies Act, 1956. It manufactures C.R. Coils/Strips, G.P. Coils/Strips and G.C. Sheets at its industrial unit located at Industrial Area, Sahibabad, Ghaziabad. For energising its plant, revisionist uses ‘RLNG’, after purchasing it from GAIL, pursuant to a Gas Sale Agreement, executed from time to time. One such agreement dated 20th February, 2013 is on record.

3. Natural Gas supplied to the revisionist by GAIL is imported. The proces