Challenging a Bombay High Court order on January 10 that dismissed its plea, Vedanta said the impugned levy is a tax and not a fee since it did not receive any special benefit, either individually or as a member of a class, which the Supreme Court has held to be a requirement for a levy to qualify as a fee in the case of Jalkal Vibhag Nagar Nigam vs Pradeshiya Industrial and Investment Co.