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The Revenue is undoubtedly correct in submitting that the DVAT Tribunal has granted significant relief to the petitioners. At the same time, the Court notices that the declaration of law by the Supreme Court was in respect of almost the nature of the transactions as in this case; they do not prima facie differ from the facts that led to the judgment of the Division Bench (as endorsed by the Supreme Court).

No significant material particulars were shown to distinguish the two cases. In the circumstances, this Court is of the opinion that the impugned orders to the extent that they direct the petitioners to deposit 20 of the tax and interest demanded and 10 penalty assessed cannot be sustained. The Court was informed during the hearing that the DVAT Tribunal, which is seized of the appeals, is likely to hear them on 01.