Central sales tax forfeiture requires express statutory authority; State law cannot create the consequence where the central Act is silent.

For central sales tax, forfeiture of excess tax collected by a registered dealer cannot be imposed through the Andhra Pradesh General Sales Tax Act when the Central Sales Tax Act contains no substantive forfeiture provision. The governing principle is that State sales tax law cannot create a substantive consequence for central sales tax administration where the central enactment is silent, and forfeiture is not a mere procedural incident. Applying that rule, the State authorities lacked power to order forfeiture of excess tax collected but not remitted, and the challenge to the forfeiture order succeeded.

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Issues: Whether, in the absence of a substantive provision in the Central Sales Tax Act, 1956 authorising forfeiture of excess tax collected by a registered dealer, the Revenue could invoke the Andhra Pradesh General Sales Tax Act, 1957 to order forfeiture.

Analysis: The statutory scheme under the Central Sales Tax Act, 1956 was examined in the light of the settled principle that where the central enactment is silent on a substantive levy or consequence, the State sales tax law cannot be used to create that consequence. Forfeiture is a substantive consequence and cannot be treated as a mere procedural incident. Since the Central Sales Tax Act, 1956 did not contain a provision authorising forfeiture of excess tax collected but not remitted, the State authorities could not derive such power from the Andhra Pradesh General Sales Tax Act, 1957. The reasoning was consistent with the rule that State authorities administering central sales tax must apply only the substantive provisions of the central enactment.

Conclusion: The Revenue had no authority to order forfeiture under the State Act in the absence of a corresponding substantive provision in the Central Sales Tax Act, 1956.

Final Conclusion: The revisions failed and the assessee's challenge to the forfeiture order was upheld.

Ratio Decidendi: A State sales tax enactment cannot be invoked to impose forfeiture in relation to central sales tax unless the Central Sales Tax Act itself contains a substantive provision authorising such forfeiture.

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