Statutory entitlement to 'C' forms cannot be defeated by grounds outside the governing rules or pending challenge to a High Court ruling.

A registered dealer's entitlement to concessional inter-State purchases through 'C' forms cannot be curtailed on grounds beyond those permitted by rule 6 of the Central Sales Tax (Orissa) Rules, and the issuing authority must act judicially and record reasons for any reduction in supply. The law declared by the High Court remains binding on subordinate revenue authorities unless stayed or set aside, and mere admission of a special leave petition does not suspend that binding force. Disputed entry tax issues may be examined in regular assessment after due hearing, but they cannot be used indirectly to suspend the registration certificate or withhold statutory forms.

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Issues: (i) Whether a registered dealer entitled to purchase goods from outside the State can be refused adequate 'C' forms on grounds other than those stated in rule 6 of the Central Sales Tax (Orissa) Rules, 1957. (ii) Whether the earlier judgment of the High Court remained binding on the Revenue authorities despite the pendency of an admitted special leave petition before the Supreme Court. (iii) Whether the Revenue authorities could suspend the dealer's registration certificate or proceed on the footing of entry tax liability while withholding 'C' forms.

Issue (i): Whether a registered dealer entitled to purchase goods from outside the State can be refused adequate 'C' forms on grounds other than those stated in rule 6 of the Central Sales Tax (Orissa) Rules, 1957.

Analysis: Section 8 of the Central Sales Tax Act, 1956 confers the concessional inter-State tax regime and makes the furnishing of declaration in form 'C' central to that scheme. Rule 12 of the Central Sales Tax (Registration and Turnover) Rules, 1957 prescribes the form, while rule 6 of the Central Sales Tax (Orissa) Rules, 1957 governs the issue, custody and supply of blank declaration forms. Once the dealer satisfies the prescribed conditions, the authority is bound to issue the forms and may refuse or regulate supply only on grounds recognised by rule 6. The authority must exercise any discretion judicially, record reasons for reduction in supply, and cannot use the form-issuing process to decide disputed tax liability.

Conclusion: The refusal of adequate 'C' forms on grounds outside rule 6 was impermissible, and the dealer was entitled to have its application considered in accordance with law.

Issue (ii): Whether the earlier judgment of the High Court remained binding on the Revenue authorities despite the pendency of an admitted special leave petition before the Supreme Court.

Analysis: The law declared by the High Court binds authorities and tribunals subordinate to it unless operation of that judgment is stayed by a competent court. Mere admission of a special leave petition does not suspend the binding force of the judgment. Judicial discipline requires subordinate revenue officers to follow the existing judgment until it is stayed or set aside.

Conclusion: The earlier judgment of the High Court continued to bind the Revenue authorities notwithstanding the pending special leave petition.

Issue (iii): Whether the Revenue authorities could suspend the dealer's registration certificate or proceed on the footing of entry tax liability while withholding 'C' forms.

Analysis: The Court held that disputed questions whether the goods were manufactured within the State or attracted entry tax could not be finally decided in the writ proceeding. Those matters could be examined in regular assessment after giving the dealer a reasonable opportunity of hearing and confronting the material relied on by the Revenue. However, the disputed entry tax question could not be used as a ground to suspend the registration certificate or withhold statutory forms. The authority could regulate assessment, but not disable the dealer's statutory entitlement to 'C' forms by indirect means.

Conclusion: Suspension of the registration certificate was not permitted, though assessment on the disputed entry tax issue could proceed in accordance with law.

Final Conclusion: The dealer's entitlement to 'C' forms was protected, the Revenue was bound by the prevailing High Court ruling, and the authorities could not suspend registration on the basis of disputed entry tax liability, though regular assessment could continue after due hearing.

Ratio Decidendi: A statutory entitlement to declaration forms under the Central Sales Tax regime cannot be defeated by withholding forms on grounds outside the governing rules, and a High Court judgment remains binding on subordinate revenue authorities until stayed or reversed.

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