Recognition certificate finality prevents assessing officers from re-litigating included goods and denying sales deduction benefits.

A registered dealer selling to a recognised dealer could rely on the recognition certificate for deduction of sales against form 15, where the relevant goods were included in the certificate's appended list. The assessing authority could not disregard that inclusion and deny the benefit on the ground that the packing labels should have been excluded under the statute, because the Commissioner or delegated authority was required to determine the excluded categories at the recognition stage. Once granted, the certificate operated as a binding determination for assessment purposes and could not be re-opened by a third-party assessing officer.

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Issues: Whether, for the purpose of allowing deduction of sales against form 15, the assessing authority could ignore the inclusion of packing labels in the purchasing dealer's recognition certificate and deny the benefit on the ground that such goods were in fact excluded from recognition under the statute.

Analysis: A registered dealer selling goods to a recognised dealer was entitled to rely on the recognition certificate issued under the statutory scheme. The Commissioner or delegated authority was required to decide, after enquiry, whether the goods claimed fell within the excluded categories before granting recognition. Once the certificate was granted and the relevant goods were included in the appended list, that determination operated as a binding finding for purposes of assessment, and a third-party assessing officer could not re-open the correctness of the inclusion. Permitting each assessing authority to re-judge the same certificate would undermine its finality and create inconsistent results.

Conclusion: The assessing authority was not entitled to disallow the deduction on the ground that the packing labels ought not to have been included in the recognition certificate. The issue was answered in favour of the assessee.

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