Form F under CST Section 6A and reassessment jurisdiction require inquiry, opportunity, and proof before reopening completed assessment.

Section 6A of the Central Sales Tax Act places the burden on the dealer to prove that movement of goods to another place of business was otherwise than by sale, and that burden may be discharged by furnishing Form F with despatch evidence. A finding under section 6A(2) requires the assessing authority to be satisfied, after inquiry, that the declaration particulars are true. The document notes a challenge to reopening completed assessment proceedings on jurisdictional and change-of-opinion grounds, and also records that the reassessment was made without adequate opportunity to produce supporting documents. The reassessment order and High Court judgment were set aside, and the matter was remitted for fresh decision after full opportunity and consideration of the jurisdictional objection and the effect of Form F.

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Issues: Whether reassessment proceedings could be reopened where the dealer had furnished Form F and challenged the very jurisdiction to reopen the completed assessment, and whether the reassessment order could stand when adequate opportunity was not granted to produce supporting material.

Analysis: Section 6A of the Central Sales Tax Act, 1956 places the burden on the dealer to prove that movement of goods to another place of business was otherwise than by sale, and permits discharge of that burden by furnishing Form F along with evidence of despatch. A finding under section 6A(2) depends upon the assessing authority being satisfied, after inquiry, that the declaration particulars are true. In the present case, the reassessment was challenged on the ground that reopening itself was without jurisdiction, that the earlier assessment could not be reopened in respect of transactions covered by Form F, and that the reassessment involved a change of opinion. The record also showed that the matter was decided without granting adequate time to produce relevant documents, rendering the reassessment effectively ex parte.

Conclusion: The reassessment order and the High Court judgment were set aside, and the matter was remitted to the assessing authority for fresh decision after giving full opportunity to the appellant and considering the jurisdictional objection and the effect of Form F.

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