ORDER

1. The petitioner has filed the present petition against the following order:-

[i] Order dated 10.12.2020 passed in case No.14/2020 by Authority for Advance Ruling, M.P.

[ii] Order dated 26.07.2021 passed in case No. MP/AAAR/05/2021 by M.P. Appellate Authority for Advance Ruling.

2. The Petitioner is a Works Contractor engaged in executing works related to the construction of the irrigation dam. The petitioner is duly registered under Central Goods and Services Tax Act, 2017 in various states. In the State of Madhya Pradesh, the petitioner is holding GSTN 23AFYPM0856K1ZW.

3. M/s Navayuga Engineering Company Ltd. had entered in to an agreement dated 19.08.2015 for the execution of certain work relating to the Narmada Valley Project. Some part of the work was sublet to the petitioner which was executed from the period 22.01.2017 to 25.01.2018.

4. Premises of the petitioner was searched by the authorities of the Director-General of Goods and Service Tax Intelligence and found evasion of GST. Vide notice dated 21.05.2020, the petitioner was called upon to discharge the remaining GST liability in Form DRC-03 at the applicable rate of 18% on works contract services supplied as a sub-cont