Job-work exemption evidence may be proved before the assessing authority even without Form F in statutory proceedings.

The article notes that where a tax issue has already been decided, it is not to be re-adjudicated in the same proceeding, and the constitutional challenge and connected issues were treated as concluded. It further states that, in reassessment or exemption proceedings, the assessee may still establish through cogent evidence that goods were brought into the State only for job work and that the finished goods were returned to principals outside the State, even where the statutory certificate or Form F is not produced. The substantive tax question was left to be determined by the assessing or appellate authority under the procedure prescribed by the Act, with no fresh relief granted in the application.

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Issues: Whether the petitioners were entitled to have the assessment or reassessment authorities accept proof of job work and return of goods by evidence other than the statutory certificate or Form F, and whether the earlier decision on the issue required fresh adjudication.

Analysis: The order records that the constitutional challenge and the connected issues had already been decided earlier, and that questions relating to reassessment or exemption were to be dealt with under the procedure prescribed by the Act. It further states that the petitioners may satisfy the assessing authority by cogent evidence showing that the imported goods were brought into the State only for job work and that the finished goods were returned to principals outside the State. The Court declined to re-adjudicate the issue again, since it had already been decided, and preserved the petitioners' opportunity to establish their claim before the assessing or appellate authority.

Conclusion: The application did not result in any fresh determination on the tax liability and was disposed of with liberty to the petitioners to adduce proof before the competent authority.

Final Conclusion: The order left the substantive tax question to be worked out in the pending assessment or appellate proceedings and granted no independent relief in the application.

Ratio Decidendi: Where a tax issue has already been decided, the assessing authority may still determine the factual entitlement to exemption or treatment of job-work transactions on the basis of cogent evidence produced in the statutory proceedings.

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