The Court made the following Order:

(per Hon’ble Sri Justice R. Raghunandan Rao)

Heard Sri Harish Kumar Rasineni, learned counsel for the petitioner and Sri Dilip Jayaram, learned counsel for the 1^st respondent and Sri Nagaraju Naguru, learned counsel for the 2^nd respondent and Sri Y.N. Vivekananda, learned Standing Counsel for the respondents 3 to 6.

2. The petitioner operates air conditioned buses and non-air conditioned buses, under the contract carriage permits, between Anantapur and Hyderabad and other routes. The petitioner had received a notice, dated 30.05.2016, calling upon the petitioner to register with the Tax Department and pay service tax on the operation of the air conditioned buses. The petitioner was also informed that transportation of passengers by air conditioned buses, on contract carriage, had become taxable from 11.07.2014 onwards. The petitioner is said to have responded to the said notice by way of reply, dated 01.05.2019, furnishing the details of the booking donethrougha online ticketing agency.

3. The petitioner contends that,at that stage, the petitioner became aware of a tax dispute resolution scheme known as “Sabkha Vishwas (Legacy Dispute Resolution)” S