Exemption based on valid Form 25 declarations survives later retrospective cancellation of the purchaser's registration.

An assessee claiming exemption on the basis of Form 25 declarations was protected where the purchasing dealers held valid registration certificates on the dates of the transactions. Subsequent retrospective cancellation of those certificates did not invalidate declarations already issued when the certificates were operative. On that reasoning, the exemption claim was upheld and the revisions failed.

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Issues: Whether the assessee was entitled to exemption on the strength of Form 25 declarations issued by purchasing dealers whose registration certificates were cancelled retrospectively.

Analysis: The purchasing dealers held valid registration certificates on the dates when the Form 25 declarations were issued. The subsequent retrospective cancellation of those certificates did not affect the validity of the declarations at the time of the transactions. On that footing, the assessee's claim to exemption was upheld.

Conclusion: The assessee was entitled to the exemption claimed, and the revisions failed.

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