Finality of Form F assessment bars reassessment where stock transfer is conclusively accepted under the Central Sales Tax Act.

A conclusive determination under section 6A(2) of the Central Sales Tax Act on whether goods were transferred to a branch or agent, rather than sold in inter-State trade, attains finality once Form F is accepted. That jurisdictional fact cannot be reopened in reassessment under the State Act merely on a later view that the original assessment was erroneous or involved a change of opinion. The special scheme of the Central Sales Tax Act prevails in this context, and the reassessment orders were set aside.

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Issues: Whether the assessment order under section 6A(2) of the Central Sales Tax Act, 1956, based on Form F, could be reopened in reassessment proceedings under the State Act.

Analysis: The assessment had originally accepted the exemption claim on the basis of Form F. The decision treats the determination under section 6A(2) as one resting on the jurisdictional fact whether the goods were transferred to a branch or agent and not sold in the course of inter-State trade. Once that fact is determined by the statutory authority, the order attains finality and cannot be reopened merely because the assessing authority considers the earlier view to be erroneous or seeks a different opinion. The ruling proceeds on the basis that the special provision under the Central Sales Tax Act excludes contrary reassessment under the State Act in such a case.

Conclusion: Reopening of the concluded determination on Form F was not permissible.

Final Conclusion: The writ petitions were allowed and the reassessment orders were set aside.

Ratio Decidendi: A conclusive determination under section 6A(2) of the Central Sales Tax Act, 1956 on the jurisdictional fact relating to stock transfer or inter-State sale cannot be reopened under reassessment on the basis of a mere change of opinion or alleged error in the original view.

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