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Issues: Whether tax could be levied on actual sale consideration rather than assessable value of goods, and whether the assessee had proved that the sale consideration was lower than the assessable value.
Analysis: The appellate authority held that tax was leviable on the actual sale consideration and not on the assessable value of goods. It further found that the assessing authority had proceeded merely on the basis of the price reflected in excise proceedings, without any material showing that the assessee had disclosed a wrong consideration in its returns.
Conclusion: The orders of the appellate authority and the Tax Board suffered from no illegality, and the revision was liable to be dismissed.