Trade Tax Tribunal's Seizure Order Upheld by Allahabad HC, Undervaluation Not Sole Basis

The Allahabad HC dismissed the Trade Tax Department's revisions against the Trade Tax Tribunal's order seizing goods of M/s. Delhi Calcutta Carrying Corporation. The Tribunal's decision was upheld, emphasizing that undervaluation alone did not warrant seizure, and Sales Tax liability should be determined in regular assessment proceedings.

---

---

Issues: Whether goods transported with valid Form 31 and accompanying documents could be seized merely on the ground that the invoices appeared undervalued.

Analysis: The goods were found to be accompanied by valid Form 31 and other relevant documents, and the Tribunal recorded a factual finding to that effect. Mere suspicion of undervaluation, without more, was not treated as a sufficient basis for seizure. Any question regarding the correct taxable value was held to be a matter for regular assessment proceedings.

Conclusion: Seizure was not justified on the ground of undervaluation alone when the consignment was supported by valid documents; the revisional challenge failed.

---