The Government of India issued directives to the Neyveli Lignite Corporation Limited (hereinafter referred to as " NLC") to divert energy to the Union Territory of Puducherry to the extent indicated in the Government Order. The agreement executed between the NLC and Tamil Nadu Electricity Board (hereinafter referred to as "TNEB") on 9 March 2001 contained a mandatory provision that supply should be made to the Union Territory of Puducherry treating the transaction as an inter - state sale. The TNEB initially supplied electricity to Puducherry treating it as an industrial consumer and collected only the cost payable to NLC together with wheeling charges at 10 paise per KWH. However, in the subsequent Order issued by the Government of