Form F acceptance under CST Act is not conclusive finality and remains open to reopening under State machinery provisions.

Section 6-A of the Central Sales Tax Act was treated as an evidentiary provision, placing the burden on the dealer to prove that inter-State movement resulted from transfer and not sale; the word "deemed" did not create a conclusive presumption or finality, so acceptance of form F remained open to reopening or revision. An order accepting form F was held to be part of the assessment process, not an independent order immune from the State sales tax reopening machinery applied through section 9(2); amenability to reopening depended on the applicable State provisions and the factual nature of the transactions.

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Issues: (i) Whether section 6-A of the Central Sales Tax Act creates a conclusive presumption and gives finality to an order accepting form F so as to bar reopening or revision. (ii) Whether an order accepting form F is an independent order outside the assessment process and immune from the reopening powers under the State sales tax law read with section 9(2) of the Central Sales Tax Act.

Issue (i): Whether section 6-A of the Central Sales Tax Act creates a conclusive presumption and gives finality to an order accepting form F so as to bar reopening or revision.

Analysis: Section 6-A was held to be a rule of evidence placing the burden on the dealer to prove that inter-State movement of goods was occasioned by transfer and not by sale. The use of the word "deemed" in section 6-A(2) did not create a conclusive presumption. The provision did not elevate the acceptance of form F to a status higher than other statutory orders. The Court held that Parliament had not expressed an intention to make the deemed result final and conclusive, and therefore the acceptance of form F remained subject to the statutory scheme governing reopening and revision.

Conclusion: Section 6-A does not create a conclusive presumption, and an order accepting form F is not immune from reopening or revision.

Issue (ii): Whether an order accepting form F is an independent order outside the assessment process and immune from the reopening powers under the State sales tax law read with section 9(2) of the Central Sales Tax Act.

Analysis: The Court held that an order under section 6-A is ordinarily made during, and is integrally connected with, assessment proceedings. It is part and parcel of the assessment process, even if passed earlier than the assessment order. By reason of section 9(2), the machinery provisions of the State sales tax enactment apply, and therefore the reopening and revision powers available under the State law can extend to such orders. The Court also held that the challenge to reopening involved questions of fact concerning the true nature of the transactions, which could not be finally decided in the appeals on the material before it.

Conclusion: An order accepting form F is not an /independent order immune from reopening, and its amenability depends on the reopening and revision provisions of the State law applied through section 9(2).

Final Conclusion: The appeals failed on the legal questions urged, leaving the departmental proceedings and the statutory appellate process to continue in the manner indicated by the Court.

Ratio Decidendi: Section 6-A of the Central Sales Tax Act is an evidentiary provision, not a source of conclusive finality; an order accepting form F is part of the assessment process and remains subject to reopening or revision under the applicable State machinery provisions applied through section 9(2).

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