Concessional sales tax rate requires strict compliance with every cumulative condition, not just the purchaser's declaration.

A concessionary sales tax rate under section 5(3) of the Kerala General Sales Tax Act, 1963 applies only when all cumulative statutory conditions are met. The dealer must not only furnish the purchasing dealer's declaration in the prescribed form, but must also prove that the goods sold are capable of being used as component parts of goods listed in the First Schedule. Mere production of the declaration is insufficient without establishing that statutory nexus, and the reduced rate cannot be claimed unless both requirements are independently satisfied.

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Issues: Whether a selling dealer claiming the reduced rate of tax under section 5(3) of the Kerala General Sales Tax Act, 1963 is required only to furnish the purchasing dealer's declaration or must also establish that the goods sold are capable of being used as component parts of goods mentioned in the First Schedule.

Analysis: Section 5(3) was read as a whole and the concessional rate was held to be available only if both statutory requirements were satisfied. The first proviso required the dealer to produce the purchasing dealer's declaration in the prescribed form, while the second proviso independently required proof that the goods sold were capable of being used as component parts of goods mentioned in the First Schedule. Mere production of the declaration was therefore insufficient without establishing the necessary nexus between the goods sold and the scheduled goods.

Conclusion: The assessee was not entitled to the reduced rate merely by furnishing the declaration and failed to establish the additional statutory requirement.

Ratio Decidendi: A concessionary tax provision must be strictly complied with, and where the statute imposes multiple cumulative conditions for concessional treatment, all such conditions must be independently satisfied before the reduced rate can be claimed.

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