Last purchase point exemption survives later cancellation of buyer registration where seller relied on valid declarations.

A bona fide selling dealer who obtained Form No. 25 declarations from purchasers validly registered at the time of sale remained entitled to last purchase point sales tax exemption. The Kerala General Sales Tax Act registration conferred statutory status, and Rule 32(14) required the seller to rely on the purchaser's declaration to show the seller was not the last purchaser liable to tax. Subsequent retrospective cancellation of the purchasers' registrations could not defeat completed transactions or deny the exemption, absent proof of collusion.

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Issues: Whether exemption from sales tax on goods taxable at the last purchase point could be denied to the selling dealer solely because the purchasing dealers' registration certificates were cancelled retrospectively, notwithstanding production of form No. 25 declarations issued when the purchasers were registered dealers.

Analysis: Registration under the Kerala General Sales Tax Act is granted only after enquiry and confers statutory status and privileges on the registered dealer. Rule 32(14) requires the seller to obtain form No. 25 from the purchaser to establish that the seller is not the last purchaser liable to tax. Once the declarations were issued by dealers who held valid registration on the date of the transactions, the seller acted bona fide on the faith of the statutory certificates and declarations. Subsequent cancellation of the purchasers' registrations could not operate retrospectively to prejudice completed transactions, especially where no collusion between the seller and the purchasers was alleged or proved.

Conclusion: The exemption could not be denied on the basis of later retrospective cancellation of the purchasers' registration certificates, and the assessee was entitled to the exemption claimed.

Ratio Decidendi: A bona fide selling dealer who obtains form No. 25 declarations from purchasers validly registered at the time of sale is entitled to the last purchase point exemption, and subsequent retrospective cancellation of the purchasers' registration cannot defeat that exemption absent collusion.

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