Mining explosives qualify for C forms when record shows their use in mining operations, supporting re-incorporation in registration records.

Where the record showed that explosives were purchased for use in mining operations, the assessee was entitled to have them included in the registration certificate and to obtain C forms for such purchases. The Madras HC noted that earlier appellate and revisional findings in penalty proceedings under the Central Sales Tax Act had already recognised the mining use of explosives, and that blasting and excavation in mining could not be denied the benefit of C forms. In the absence of any counter-affidavit, and consistent with the connected mandamus already granted, the writ petition was allowed and the authorities were directed to re-incorporate explosives in the registration certificate.

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Issues: Whether the assessee was entitled to re-incorporation of explosives in the registration certificate and consequential issuance of C forms for purchase of explosives used in mining activities.

Analysis: The registration certificate had been amended to delete explosives, but the earlier appellate and revisional orders, passed in penalty proceedings under section 10A of the Central Sales Tax Act, 1956, had recognised that explosives were purchased for use in mining. The authorities' own findings showed that explosives used for blasting rocks and excavation in mining could not be denied the benefit of C forms. In the absence of any counter-affidavit, and in view of the earlier mandamus granted in the connected matter, the request for re-incorporation was supported by the record.

Conclusion: The assessee was entitled to the relief sought, and the writ petition was allowed with a mandamus to re-incorporate explosives in the registration certificate.

Ratio Decidendi: Where the record establishes that explosives are intended for and used in mining operations, the assessee is entitled to have them included in the registration certificate and to obtain C forms for such purchases.

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