The Court made the following Common Order: (per Hon’ble Sri Justice R. Raghunandan Rao)

Heard Sri Karthik Ramana Puttam Reddy, learned counsel for the petitioner and the learned Government Pleader for Commercial tax, appearing for the respondents.

2. The petitioner, who is registered under the Central Goods and Services Tax Act (CGST) and the State Goods and Services Tax Act (SGST) 2017, is in the business of designing, manufacturing, supplying, developing, assembling, erecting and installing Wind Turbine Generators. The petitioner, in the course of its business, during the periods 2017-2018 and 2018-2019, had entered into various contracts for manufacture and erection of Wind Turbine Generators, for its customers. The petitioner treated these contracts as composite supplies of goods and services and paid tax @ 5%. However, the 1^st respondent initiated assessment proceedings on the ground that the contracts executed by the petitioner should be treated as works contracts involving immovable property, taxable @ 18%. The 1^st respondent, had passed two separate Orders of Assessment, for the periods July 2017 to March 2018 and April 2018 to September 2019 (the disputed turn-over is only u