Independent cash memo obligations justified rejection of accounts where statutory records were not maintained.

The High Court treated the duty to issue cash memos and credit memos under Section 8-A(3) as independent from the general obligation to keep true and correct accounts under Section 12. It held that the later insertion of Section 8-A(4) did not assist the assessee for the relevant assessment year. The omission to issue the prescribed documents could properly be considered by sales tax authorities in assessing the reliability of the books, and the accounts could be rejected where the business was substantial and no contrary trade practice was shown.

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Issues: Whether the assessee's accounts could be rejected for failure to issue cash memos and credit memos in compliance with Section 8-A(3), notwithstanding the later insertion of Section 8-A(4) and the contention that such documents were not customary in that line of business.

Analysis: Section 12 required dealers to maintain true and correct accounts of purchases and sales. Section 8-A(3) separately required every registered dealer who realised tax on sales to issue cash memos or credit memos and to keep the requisite counterfoils and records. The statutory obligation under Section 8-A(3) was treated as independent of the general accounting requirement under Section 12. The fact that Section 8-A(4) was introduced later did not assist the assessee for the relevant assessment year. The Court also held that the omission to issue cash memos and credit memos could legitimately be taken into account by the sales tax authorities in judging the reliability of the accounts and in rejecting them, especially where the assessee's business was substantial and there was no material showing any different practice.

Conclusion: The accounts were validly rejected, and the assessee's challenge failed.

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