Tax-paid status under Central sales tax, not mere purchase from a registered dealer, governs relief on subsequent sale.

For liability on a further sale, proof that goods were purchased from a registered dealer was held insufficient by itself. The Court stated that relief depended on the goods being tax-paid under the Central Sales Tax regime at the relevant inter-State stage. Because Central sales tax had not been paid, the Tribunal's basis for deleting the demand was unsustainable, and the demand was restored. The ruling thus treats tax-paid status under the inter-State sale, not mere purchase from a registered dealer, as the ative condition for exemption or relief on subsequent sale.

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Issues: Whether, for the purpose of liability on further sale, it is sufficient that the goods were purchased from a registered dealer, or whether it is additionally necessary that Central sales tax had been paid at the time of the inter-State sale.

Analysis: The revision turned on the liability attached to subsequent sale of goods purchased in inter-State trade. The Tribunal had accepted the assessee's claim on the footing that the purchase was from a registered dealer. The Court held that this was not enough by itself. The relevant requirement was that the goods must have been tax-paid under the Central Sales Tax regime at the time of the inter-State sale. As Central sales tax had not been paid, the demand could not have been deleted on the basis accepted by the Tribunal.

Conclusion: The issue was answered in favour of the Revenue. The Tribunal's order was unsustainable and the demand restored.

Final Conclusion: The revision succeeded, the Tribunal's decision was set aside, and the assessment order was sustained.

Ratio Decidendi: For exemption or relief on a subsequent sale, proof of purchase from a registered dealer is insufficient unless the goods are shown to be tax-paid under the Central Sales Tax law at the relevant inter-State stage.

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