Concessional sales tax cannot be denied when the seller holds a valid declaration form despite disputes over the buyer's end use.

Once a selling dealer furnishes a valid Form XVII declaration for concessional tax under section 3(3) of the Tamil Nadu General Sales Tax Act, the concession cannot be denied by questioning whether the declared end use was correct or whether the goods were in fact a component part of the finished product. The statutory scheme places the burden of any false or wrong declaration on the purchasing dealer, and later amendments confirming purchaser liability reinforce that the seller need not verify the truth of the declaration beyond its prescribed form. The tribunal's view was therefore affirmed and the revision to deny the concession failed.

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Issues: Whether the assessee was entitled to the concessional rate of tax on sales of transformer oil on the basis of valid form XVII declarations under section 3(3) of the Tamil Nadu General Sales Tax Act, 1959, and whether the selling dealer could be denied the concession on the ground that the goods were not in fact a component part of the finished product.

Analysis: The concessional scheme under section 3(3) required the selling dealer to furnish the prescribed declaration form. The Court noted that the statutory explanation defined a component part as an identifiable constituent of the finished product, but relied on the settled rule that the seller is not required to verify the truthfulness or actual use of the purchasing dealer's declaration once the prescribed form is duly furnished. The subsequent amendments introducing liability on the purchaser for misuse or wrong declaration reinforced that the statute placed the burden of incorrect use on the purchasing dealer and not on the selling dealer.

Conclusion: The assessee was entitled to the concessional rate, and the revenue's revision failed.

Final Conclusion: The tribunal's view was affirmed and the assessment could not be revised to deny the concessional rate merely because the department disputed the purchaser's declaration.

Ratio Decidendi: Once the selling dealer furnishes a valid declaration in the prescribed form, entitlement to concessional tax under section 3(3) cannot be denied by questioning the correctness of the purchaser's declared end use; any false declaration is visited on the purchaser under the statute.

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