Statutory security for sales tax registration can be enforced through revenue recovery for arrears collection.

Immovable property furnished as security at sales tax registration can be proceeded against for recovery of the dealer's arrears when the statutory scheme treats that security as available for realisation of tax payable. Reading the registration provisions and the revenue recovery law together, the Tribunal noted that security given under the Tamil Nadu General Sales Tax Act was enforceable through the same recovery machinery applicable to revenue defaulters and sureties. The auction notice was therefore upheld, and the challenge failed because the secured tax dues could be enforced against the property offered as security.

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Issues: Whether the immovable property furnished as security for registration under the sales tax law could be proceeded against for recovery of the dealer's tax arrears under the revenue recovery .

Analysis: The security was furnished under the registration provisions of the Tamil Nadu General Sales Tax Act, 1959, and the rules permitted immovable property as a form of security. Section 21(2-B) indicated that security obtained at registration served the purpose of realisation of tax payable, and section 50 of the Tamil Nadu Revenue Recovery Act, 1864 authorised enforcement against sureties by the same remedies available against revenue defaulters. Reading these provisions together, the furnishing of property as security created liability in respect of the tax arrears secured, and the revenue authorities were entitled to proceed against that property.

Conclusion: The property given as security was liable to be proceeded against for recovery of the tax arrears, and the challenge to the auction notice failed.

Final Conclusion: The petition was dismissed because the statutory security could be enforced for recovery of the sales tax dues, leaving the petitioner to pursue any civil remedy available.

Ratio Decidendi: Where immovable property is furnished as security under the sales tax registration framework, the revenue recovery machinery may be invoked against that security for collection of the secured tax arrears.

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