JUDGMENT : Markandey Katju, J. This order shall dispose of Civil Appeal No. 6982 of 2005 and Civil Appeal No. 6983 of 2005. The facts giving rise to these appeals are taken from the case of Tata Iron & Steel Co. Ltd. v. State of Jharkhand & Others reported in (2004) 7 SCC 242 between the parties pertaining to same dispute. 2. Tata Iron & Steel Co. Ltd., the respondent herein, had established a manufacturing unit for production of HRP, rounds, structurals and other iron and steel products in Dhanbad which was then in the erstwhile State of Bihar. The State of Bihar in the year 1995 evolved a new industrial policy with a view to create an environment conducive to growth of industries in the State and to utilise its optimum advantage all the resources available in the form of surface and groundwater, fertile land, mineral wealth, disciplined and skilled manpower, etc. By the said policy the Government tried to attract investors from various parts of the country to invest in identified thrust areas, as also for creation of essential infrastructure including private generation. One of the areas which the said industrial policy sought to develop was the field of metallurgical industries. As an incentive to attract investment in the State among others, the said policy provided for sales tax incentives which included exemption for new units in Category 'B' districts, 8 years' sales tax exemption on sale and purchase of materials from the date of commencement of production by such units located in Category 'B' districts. In pursuance of the said policy, necessary exemption notifications under Section 7 of the Bihar Finance Act, 1981 (hereinafter referred to as 'the Act') were also issued. 3. The respondent having noticed the incentives offered by the State Government, by letter dated 30.4.1997 intimated the then Chief Minister of the State that it has a plan for installing a cold-rolling mill in Jamshedpur in which a sum of Rs. 2000 crores was to be invested if the financial climate in the State was favourable. Therefore, before taking a final decision in this regard, it sought a confirmation from the State of Bihar as to its commitment to grant sales tax exemption as stated above. 2000 crores was to be invested if the financial climate in the State was favourable. Therefore, before taking a final decision in this regard, it sought a confirmation from the State of Bihar as to its commitment to grant sales tax exemption as stated above. By that letter the respondent also requested the Chief Minister to authorise the Secretary to the Department of Industries and other officials of the State to have a discussion with the respondent about the plan in detail and to guide the respondent in the manner in which it could enjoy the benefits of sales tax incentives. 4. Pursuant to the above request letter of the respondent, a High Power Committee was constituted. In pursuance to the recommendations made by the High Power Committee, the Government of Bihar amended the Industrial Policy Resolution, 1995 bringing it in conformity with the decision taken at the meeting of the High Power Committee on 21.7.1997. 5. By a letter dated 16.4.1999 the Commissioner and Secretary, Government of Bihar, reassured the respondent that the Central sales tax and Bihar sales tax, both will be exempted as provided in the policy in regard to the purchase and sale of cold-rolling mill. The said letter also assured that if production in the new unit of the respondent started in the year 1997 such benefit of exemption would be available up to the year 2005. It also assured that even if the industrial policy expired, the facilities granted to the respondent will continue till a period of 8 years from the date of production. 6. On 15.11.2000 under the Bihar Reorganisation Act, 2000, a part of Bihar which included Jamshedpur, became a new State named as Jharkhand which is the successor State of State of Bihar. On 3.4.2001, the Commissioner of Commercial Taxes (CCT) suo moto in exercise of powers under Section 46(4) of the Act held that the respondent is not entitled to get the said exemption as the alleged new products namely CRM is not a new product but the HRM and CRM both are one and the same products. 7. Aggrieved against the aforesaid order, respondent filed a writ petition being CWJC No. 1426/2001 before the High Court of Jharkhand. 8. 7. Aggrieved against the aforesaid order, respondent filed a writ petition being CWJC No. 1426/2001 before the High Court of Jharkhand. 8. The High Court accepted the writ petition and remanded the matter back to the Commissioner of Commercial Taxes for a fresh decision keeping in view the directions issued in the said order. 9. Being aggrieved, respondent filed a special leave petition in which leave was granted and ultimately this Court by judgment and order dated 25th August, 2004, reported in (2004) 7 SCC 242 , allowed the appeal, setting aside the impugned order of the High Court and restored the proposal made by the Joint Commissioner of Commercial Taxes for grant of exemption certificate to the respondent as also the exemption certificates granted consequently. 10. After the final order passed by this Court, respondent filed an application before Deputy Commissioner of Commercial Taxes (for short 'DCCT')/Joint Commissioner of Commercial Taxes (for short 'JCCT') for refund of sales tax amounting to Rs. 9,96,87,604 as paid on sale of CRM product for the financial years 2000-01 and 2001-02 and also statutory interest of Rs. 2,82,65,295/-@ 9 per cent per annum. As the said application was not decided by the DCCT/JCCT, respondent filed a writ petition No. 5375 of 2004 before the High Court of Jharkhand seeking a mandamus directing the appellants to refund the aforesaid amount of Rs. 9,96,87,604/-, illegally collected, along with statutory interest of Rs. 2,82,65,295/-. 11. The High Court, as an interim measure, by its order dated 4th October, 2004 issued the following directions: "In the meantime, the petitioner, if appears through its representative, pursuant to notice contained in letter No. 612 dated 27th September, 2004, the respondents, without insisting on production of Form XX, will decide the question of refund of amount in accordance with law, taking into consideration the decisions of this Court and the Supreme Court." 12. Since no specific decision was taken nor any order was passed by the DCCT, Urban Circle, Jamshedpur Division, Jamshedpur, suo motu contempt proceedings were initiated against Dr. K.C. Jha, Deputy Commissioner of commercial Taxes, Urban Circle, Jamshedpur Division, Jamshedpur. Later on, the said officer appeared before the High Court and informed that the JCCT(Administration) is the competent authority to decide the question of refund. 13. K.C. Jha, Deputy Commissioner of commercial Taxes, Urban Circle, Jamshedpur Division, Jamshedpur. Later on, the said officer appeared before the High Court and informed that the JCCT(Administration) is the competent authority to decide the question of refund. 13. The High Court by an interim order dated 6/15.12.2004 passed the following order: "In the meantime, the competent authority will decide the claim and pass an appropriate order. He will also file an affidavit enclosing a copy of the same as also the receipt showing service of copy of the affidavit to the petitioner, by 7th January, 2005." 14. In pursuance to the above directions, JCCT(Admn.) decided the claim of refund and statutory interest as was claimed by the respondent. Directing refund of the amount, the said officer on 4th January, 2005 passed the following order: "In the circumstances as discussed above it appears that the total refund being claimed amounting to Rs,9,96,87,607.00 is fully covered by the total excess payments amounting to Rs. 9,97,71,515.87 paisa and hence the refund as claimed amounting to Rs. 9,96,87,607.00 is refundable to the dealer company. Prepare refund voucher accordingly. 15. However, so far as the claim of statutory interest@ 9% amounting to Rs. 2,82,64,539.53 is concerned it will be dealt in separately later on." 16. Since the order of refund had already been passed by the JCCT and the same had not been challenged by the appellants, the High Court disposed of the writ petition without going into the legality or otherwise of the order passed by JCCT(Admn.) dated 4.1.2005 by observing thus: "After hearing the parties and having regard to the facts and circumstances, as the State is to determine the claim of the statutory interest and the matter is pending before the Joint Commissioner, Commercial Taxes (Administration), Jamshedpur Division, Jamshedpur, the case is remitted to the said officer with direction to decide the claim of statutory interest and thereby decide whether the petitioner is entitled for statutory interest@ 9% amount to Rs. 2,82,64,539.53 paisa and will pass a speaking order within a period of two months from the date of receipt/production of a copy of this order. It will be open for the petitioner to file a detailed representation showing the ground of claim for statutory interest. If it wants to rely on any judgment, it may enclose a photostat copy of the same. It will be open for the petitioner to file a detailed representation showing the ground of claim for statutory interest. If it wants to rely on any judgment, it may enclose a photostat copy of the same. In such case, the Joint Commissioner, Commercial Taxes (Administration), Jamshedpur Division, Jamshedpur will take into consideration the grounds, as may be taken by the petitioner. This writ petition stands disposed of, with the aforesaid observations/directions." 17. Aggrieved against the aforesaid order, the present appeal has been filed. 18. Relying upon the judgment of this Court in Mafatlal Industries Ltd. & others v. Union of India and others reported in (1997) 5 SCC 536 , it is contended by the learned senior counsel appearing for the appellants that refund cannot be granted to the respondent as it would amount to undue enrichment, as the respondent had passed on the burden to its customers. 19. We do not find any infirmity in the order passed by the High Court. The High Court has not issued a mandamus directing the appellants to refund the amount to the respondent. The amount had been ordered to be refunded by JCCT by his order dated 4th January, 2005. Appellants have not challenged the order of JCCT so far. From the reading of the impugned order, it is clear that the High Court has not opined regarding the correctness or otherwise of the order passed by the JCCT (Admn.). 20. During the course of arguments, counsel for the appellants sought liberty to revise the order passed by the JCCT in terms of Section 46(4) of the Act or permission to challenge the order passed by the JCCT. 21. Without expressing any opinion as to whether the order dated 4.1.2005 passed by the JCCT was correct or not and without making any observation regarding the maintainability of a revision petition under 22. Section 46(4) of the Act, we dismiss these appeals. It is always open to any party to take steps deemed appropriate as per advice. If any steps are taken or proceedings initiated, the same shall be disposed of in accordance with law. At this stage, counsel for the appellants expressed an apprehension that if such steps are taken then the order passed by the High Court may come in its way. If any steps are taken or proceedings initiated, the same shall be disposed of in accordance with law. At this stage, counsel for the appellants expressed an apprehension that if such steps are taken then the order passed by the High Court may come in its way. We make it clear that if any steps are taken by the appellants then the authority/court shall decide the same on its own merits in accordance with law without being influenced by any of the observations directly or indirectly made by the High Court or by this Court. 23. All contentions are left open to both the sides. 24. The Appeals stand disposed of accordingly.