C declaration forms cannot be withheld to recover tax arrears where no statutory power authorises such denial.

C declaration forms under the Central Sales Tax scheme cannot be withheld merely because an assessee has outstanding tax arrears or a pending appeal. The text states that no provision of the VAT Act or the Central Sales Tax Act authorised denial of the forms, and that statutory forms cannot be used as leverage to compel payment of dues. Recovery of arrears must instead be pursued through lawful recovery proceedings. The denial of C forms was therefore unlawful, and the forms were directed to be supplied.

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Issues: Whether the assessee could be denied C declaration forms on the ground of outstanding tax arrears and pending appeal.

Analysis: Form C under the Central Sales Tax scheme enables the purchaser to support inter-State purchases and obtain the concessional rate of tax. The denial of such statutory forms was not shown to be authorised by any provision of the VAT Act or the Central Sales Tax Act. In the absence of statutory power, C forms cannot be withheld as a device to compel payment of arrears, and recovery of dues must be pursued through lawful proceedings.

Conclusion: The denial of C declaration forms for alleged arrears was unlawful, and the respondents were directed to supply the forms.

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