Inter-State sales reassessment fails where C form defects are only procedural and purchasers were registered dealers.

Reassessment based on allegedly defective C forms for inter-State sales was held unsustainable because the purchasing dealers were in fact registered, and the discrepancy was only a procedural delay in showing registration on the date of issue. The original assessment had accepted the sales as inter-State transactions, and the defect in the forms was not treated as grave enough to justify reopening a completed assessment. On these facts, the Court rejected the reassessment and upheld the assessee's position.

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Issues: Whether reassessment could be sustained on the ground that the C forms filed in support of inter-State sales were defective because the purchasing dealers were not shown as registered on the date of issue.

Analysis: The assessment had originally accepted the transactions as inter-State sales. Reassessment was initiated only because the C forms were treated as defective. The material before the Court showed that the purchasers were in fact registered dealers, though there was a procedural delay, and the defect pointed out was not of a grave nature. On these facts, the reopening of a completed assessment was not justified.

Conclusion: Reassessment was not sustainable and the assessee succeeded.

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