Form F under section 6-A confines reassessment to a limited genuineness enquiry, barring wider reopening except for fraud or jurisdictional error.

A valid Form F declaration under section 6-A limits the assessing authority to verifying whether the goods were transferred to the assessee's branch, agent, or other place of business and whether the declaration is genuine and valid. The authority cannot enlarge the enquiry or reopen the assessment merely because later material emerges or because the earlier view was mistaken; interference is confined to cases of jurisdictional error, fraud, collusion, misrepresentation, concealment, or false particulars. The text notes that the impugned orders departed from this limited framework, while also indicating that the Revenue's materials could not be ignored entirely because the governing Supreme Court ruling had not then been available.

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Issues: Whether the reassessment and revisional orders treating the disputed transfers as inter-State sales could be sustained in view of the law governing section 6-A declarations in Form F and the scope of enquiry permissible to the assessing authority.

Analysis: The Supreme Court's later exposition of section 6-A was applied to hold that once Form F is furnished, the assessing authority must confine itself to the statutory enquiry whether the goods were in fact transferred to the assessee's branch office, agent, or other place of business and whether the declaration is valid and genuine. Any enquiry beyond that limited field is impermissible. Reopening is not justified merely because fresh material is later found or because the earlier assessment view was mistaken; interference is reserved to cases involving jurisdictional error, fraud, collusion, misrepresentation, concealment, or false particulars. The impugned orders were found to have deviated from this framework, but the materials relied upon by the Revenue could not be ignored altogether, particularly since the controlling Supreme Court ruling had not been available when the earlier exercise was undertaken.

Conclusion: The reassessment and appellate orders were set aside and the matter was remitted to the assessing authority for fresh consideration in accordance with the law declared by the Supreme Court.

Ratio Decidendi: An order passed on a valid Form F enquiry under section 6-A is conclusive except on limited grounds such as fraud, collusion, misrepresentation, concealment, or jurisdictional error, and the assessing authority cannot travel beyond the statutory scope of enquiry.

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