JUDGMENT :

Akil Kureshi, J.

The petitioner has challenged an order dated 23.04.2018 as at Annexure-8 to the petition. He has prayed for the grant of refund of a sum of Rs.24,21,007/- which was deducted from the petitioner's bills in course of execution of a work contract for the assessment period 2010-11 to 2013-14. These prayers arise in following background:

2. Petitioner is a private limited company and is dealing in laying down and installation of pipes in the field of Gas, Electric and Telecom sectors with Trenchless technology called Horizontal Directional Drilling (HDD, for short). The petitioner was awarded a work order for laying/ installation of pipes through HDD technology in the city of Agartala by one Kazstrov Services Infrastructure India Private Limited (KSS, in short) on 21.12.2010. For execution of the said work the petitioner obtained a registration under the then in force Tripura Value Added Tax Act (TVAT Act, for short) in January, 2021. In the course of the execution of the work order the petitioner as a service provider paid service tax to the Central Excise and Service Tax Department, Government of India by depositing or adjusting service tax.

3. In the course of