Writ challenge to other-State tax assessments and section 6A(2) finality under the CST Act remain limited by statutory scrutiny.

Writ jurisdiction under Article 226 cannot be used to collaterally challenge or obtain refund of tax assessed and collected by authorities of another State under that State's sales tax law. An order under section 6A(2) of the Central Sales Tax Act, made on a declaration in form F, is only a step in the assessment machinery and does not confer finality or immunity from reassessment, revision, or other statutory scrutiny where the law permits. The underlying controversy whether the movements were stock transfers or inter-State sales was left open for decision in appropriate proceedings before the competent forums.

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Issues: (i) Whether the writ petitions could be maintained before the High Court to seek refund or other relief against tax levied and collected by other State Governments under their own sales tax laws. (ii) Whether an order passed under section 6A(2) of the Central Sales Tax Act, 1956 on a declaration in form F conferred finality or immunity so as to bar reassessment, revision, or other action under the taxing statutes. (iii) Whether the assessees were entitled to any immediate substantive relief in these proceedings without adjudication on the merits of the alleged stock transfers and inter-State sales.

Issue (i): Whether the writ petitions could be maintained before the High Court to seek refund or other relief against tax levied and collected by other State Governments under their own sales tax laws.

Analysis: Relief was sought not only against the authorities of Tamil Nadu but also against authorities of other States in relation to tax paid or collected pursuant to assessments made under the respective State enactments. The jurisdiction under Article 226 could not be used to directly or indirectly challenge proceedings completed by authorities of another State in respect of events occurring within that State and under that State's law. Such orders, and the taxes paid pursuant to them, were beyond the permissible reach of these writ petitions before this Court.

Conclusion: The challenge and refund claims against the other State Governments were not maintainable before this Court and were rejected.

Issue (ii): Whether an order passed under section 6A(2) of the Central Sales Tax Act, 1956 on a declaration in form F conferred finality or immunity so as to bar reassessment, revision, or other action under the taxing statutes.

Analysis: Section 6A was held to be an ordinary legislative provision dealing with burden of proof and the manner in which a dealer may establish that movement of goods was otherwise than by reason of sale. An order under section 6A(2) was treated as part of the assessment process and only a step in aid of quantification of tax liability. It did not acquire an immutable or conclusive character beyond the reach of the statutory powers of reassessment or revision under the sales tax enactments, and it could be acted upon or reopened in accordance with law when the statutory conditions were satisfied.

Conclusion: An order under section 6A(2) does not create an absolute bar against reassessment or revision and does not confer immunity from statutory scrutiny.

Issue (iii): Whether the assessees were entitled to any immediate substantive relief in these proceedings without adjudication on the merits of the alleged stock transfers and inter-State sales.

Analysis: The parties were not invited to argue the merits of whether the individual movements of goods were really stock transfers or inter-State sales, and that controversy was expressly left open. The Court instead preserved the assessees' opportunity to make representations or pursue appeals and revisions before the competent authorities within the time granted, while declining to quash the impugned proceedings on the limited issues decided.

Conclusion: No substantive determination on the merits of the alleged transactions was made, and only limited procedural liberty was granted.

Final Conclusion: The writ petitions failed on the principal jurisdictional and legal objections, while the underlying factual controversy regarding the nature of the transactions was left open for decision in appropriate proceedings before the competent forums.

Ratio Decidendi: A declaration order under section 6A(2) is only part of the assessment machinery and remains subject to the ordinary statutory powers of reassessment and revision, while writ relief cannot be granted to collaterally challenge tax assessments made by authorities of other States in their own territorial jurisdiction.

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