Writ interference at revision notice stage is limited; purchaser may rely on proof of purchases and seller identity without proving tax payment by sellers.

At the stage of a revision notice proposing tax proceedings, a writ court ordinarily will not interfere, and the affected party may raise objections before the authority. The Court noted that the petitioner could rely on evidence showing purchases from identifiable registered dealers and was not required, on the material referred to, to prove actual remittance of sales tax by the sellers. The writ petition was therefore disposed of without deciding tax liability on merits, leaving the petitioner free to contest the proceedings before the assessing authority.

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Issues: Whether interference was warranted at the stage of a revision notice proposing tax proceedings, and whether the petitioner was required to prove that the sellers had actually paid sales tax.

Analysis: The notice was only at the initiation stage, and the Court declined to interfere in the proceedings at that point. It noted that the petitioner could place objections before the authority, including evidence that the purchases were from registered dealers whose identity could be established. The Court also indicated that, on the material referred to before it, the petitioner was not required to prove actual payment of sales tax by the sellers, if there was acceptable evidence of the purchases and the identity of the sellers.

Conclusion: No interference was called for at the notice stage, and the petitioner was left to pursue objections before the authority.

Final Conclusion: The writ petition was disposed of without adjudicating the tax liability on merits, while preserving the petitioner's opportunity to object before the assessing authority.

Ratio Decidendi: A writ court ordinarily will not interfere at the stage of a revision or show-cause notice, and a purchaser may rely on acceptable evidence of purchases and seller identity without being compelled to prove actual remittance of tax by the sellers.

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