Strict limits on sales tax inspection powers bar compelled private papers, coerced signatures, and unsupported obstruction charges.

The statutory power of inspection under the sales tax law was strictly confined to business accounts, registers, goods and premises, and had to be exercised at reasonable times. It did not authorise an to demand private papers or cash unrelated to business records, or to compel the assessee to sign a statement prepared by the officer. On the facts, obstruction was not proved, and refusal to comply with unauthorised demands during a holiday or lunch interval could not constitute the offence charged. The conviction under Section 15(c) was therefore not sustainable, and acquittal followed.

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Issues: Whether the conviction for obstructing inspection under the sales tax law was sustainable when the inspection was sought to be made on a holiday and the authority demanded production of private papers, cash and a compelled signature on a statement prepared by himself.

Analysis: The inspection power under Section 14(2) was confined to accounts, registers, goods and business premises, and had to be exercised at all reasonable times. It did not authorise compulsion to produce private papers or cash unrelated to business accounts, nor did Rule 24 empower the officer to prepare an incriminating statement and insist on the assessee's signature. On the facts, the alleged obstruction was not proved, and even the refusal to comply with unauthorised demands during a holiday or lunch interval could not amount to the offence charged.

Conclusion: The conviction under Section 15(c) was not sustainable and the assessee was entitled to acquittal.

Ratio Decidendi: The statutory power of inspection must be strictly construed and cannot be extended to compel production of private material or to require an assessee to sign a statement prepared by the officer; obstruction is punishable only when it defeats a lawful inspection exercised within the limits of the statute.

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