Security for declaration forms upheld where reasons were relevant, authority was competent, and quantum was tied to turnover.

A writ court will not interfere with an order requiring reasonable security for the proper use and safe custody of declaration forms under sales tax law where the recorded reasons are prima facie relevant and connected to the statutory purpose. Their sufficiency is not open to writ review unless they are wholly irrelevant or no reasonable authority could rely on them. The order remained valid because it was passed by the competent statutory authority after the dealer was heard, even though it followed the Commercial Tax Officer's report. Reasonableness of the security depended on taxable turnover and the need to ensure proper future use of declaration forms. The challenge failed and the security demand was upheld.

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Issues: Whether the writ court should interfere with an order demanding security for the proper use and safe custody of declaration forms under the sales tax law, on the grounds that there were no sufficient reasons, the power was improperly exercised, or the amount of security was unreasonable.

Analysis: The demand for security was made under the statutory power to require reasonable security for the proper use and safe custody of declaration forms. The reasons recorded in the order were held to be prima facie relevant and having nexus with the statutory purpose, and their sufficiency was not open to review in writ jurisdiction unless they were wholly irrelevant or such that no reasonable authority could have acted upon them. The fact that the Additional Commissioner acted after considering the Commercial Tax Officer's report did not make the order invalid, since the order was passed by the statutory authority empowered to exercise the power and the dealer had been given an opportunity to show cause. As to quantum, the reasonableness of security was held to depend not merely on the alleged tax evasion in the particular instance but on the taxable turnover and future proper use of declaration forms.

Conclusion: The challenge to the security demand failed; the impugned order was upheld.

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