Duplicate Form C verification can satisfy substantial compliance when originals are already on record and misuse risk is absent.

Duplicate Form C declarations may be accepted where the substantive declaration is already on record and no misuse is shown, because section 8(4) of the Central Sales Tax Act and rule 12(1) do not make the original physical copy indispensable in every case. The Court relied on the principle that Form C is made up of identical parts and that substantial compliance is sufficient when the original forms are already available in another assessment record. On that basis, the duplicate C forms could be verified against the originals, and the consequential exemption for the remaining turnover was available; the revisional order refusing that claim was quashed.

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Issues: Whether the assessee was entitled to concessional rate of tax and exemption on the strength of duplicate C forms when the original C forms had already been filed in the assessment of its manufacturing division.

Analysis: The dispute turned on the effect of section 8(4) of the Central Sales Tax Act, 1956 and rule 12(1) of the Central Sales Tax (Registration and Turnover) Rules, 1957, together with the State rule requiring production of the original portion of Form C. The Court applied the earlier view that Form C consists of original, duplicate and counterfoil parts, all of which are identical in substance, and that the statute does not make filing of only the original part indispensable where the declaration is otherwise duly available and identifiable. The Court distinguished the case where all originals were lost, and relied on the admitted fact that the original C forms were already on record in the manufacturing division. On that footing, the refusal to recognize the duplicate forms for the trading division was held to be unsustainable.

Conclusion: The assessee was entitled to have the duplicate C forms verified against the originals already filed in the manufacturing division and, upon verification, to receive the consequential exemption for the remaining turnover. The impugned revisional order rejecting that claim was quashed.

Ratio Decidendi: Where the substantive declaration in Form C is already on record and there is no risk of misuse, insistence on the particular physical copy marked as original is not mandatory if substantial compliance with the statutory requirement is established.

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