State sales tax rule cannot impose extra Form C restrictions beyond delegated power under the Central Sales Tax Act.

The concessional rate under the Central Sales Tax Act depended on furnishing declarations in the prescribed manner, but the form and contents of those declarations were governed by the Central Government's rule-making power. A State rule could not, under that subordinate power, impose a further restriction that a single Form C declaration must cover only one transaction, nor could it be applied to purchasing dealers outside the State's territorial reach. The Madras rule was therefore not validly applicable to the Punjab purchasing dealers, and non-compliance with that requirement could not justify denial of the concessional tax rate.

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Issues: Whether the Madras rule requiring a separate Form C declaration for each transaction could validly govern purchasing dealers outside Madras and whether non-compliance with that rule disentitled the selling dealer to the concessional rate under the Central Sales Tax Act, 1956.

Analysis: Under section 8(4) of the Central Sales Tax Act, 1956, the concessional rate depended on furnishing a declaration in the prescribed manner. The form and contents of the declaration were prescribed by the Central Government under section 13(1)(d), while the State Government's rule-making power under sections 13(3) and 13(4) was subordinate and had to remain consistent with the Act and the Central rules. The Madras rule, properly construed in the statutory scheme, was intended to regulate dealers within Madras and could not be applied to purchasing dealers in Punjab. In any event, the State Government lacked competence under sections 13(3) and 13(4) to impose a prohibition that a single declaration should not cover more than one transaction, because that field belonged to the Central rule-making power under section 13(1)(d). The defect, therefore, did not justify denial of the lower rate.

Conclusion: The requirement in rule 10(1) of the Madras Rules did not validly apply to the Punjab purchasing dealers, and the concessional tax rate could not be denied on that basis.

Ratio Decidendi: A State-made rule under the Central Sales Tax Act cannot, under the guise of prescribing the manner of furnishing declarations, impose a substantive restriction that is beyond the State's delegated competence or operate territorially against dealers outside the State.

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