C O M M O N O R D E R

By this common order, both the Writ Petitions are being disposed of.

2. In these Writ Petitions, the petitioner has challenged the impugned common order dated 16.02.2015 passed by the second respondent Appellate Deputy Commissioner (CT), Vellore in A.P.Nos.204 & 205 of 2014. By the impugned orders, the respective appeals of the petitioner were dismissed by the second respondent. These appeals were filed against two separate assessment orders dated 12.05.2014 passed by the third respondent in Rc.B1/1418/2013 for the Assessment Years 2012-2013 and 2013-2014.

3. The petitioner a unregistered dealer under the provisions of the Tamil Nadu Value Added Tax Act, 2006 was issued with a notice by the third respondent Assistant Commissioner, Ranipet (SIPCOT) on

10.01.2014 for the Assessment Years 2012-2013 and 2013-2014.

4. In the notice, it is alleged that the petitioner was providing material handling object, namely, cranes to Bharath Heavy Electricals Limited (hereinafter referred to as BHEL for brevity), the sixth respondent herein, on “transfer of right to use” basis and therefore was liable to pay tax under Section 4 of the Tamil Nadu Value Added Tax Act, 2006. The peti