Post-assessment Form I can support SEZ sales exemption, with assessment revision permitted after proper scrutiny.

Form I produced after assessment for an inter-State sale to a Special Economic Zone unit could be taken into account for exemption under the Central Sales Tax Act, and the assessment could be revised if the form withstood scrutiny. The court held that the earlier precedent allowing post-assessment production of forms was not limited to Form C or concessional-rate claims, and the concession-exemption distinction was immaterial on the facts. The authority's summary rejection of that precedent without reasons was unsustainable, and the matter had to be reconsidered under the statutory rectification route before fresh assessment in accordance with law.

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Issues: Whether Form I produced after completion of assessment under the Central Sales Tax Act could be taken into account for granting exemption in respect of sales to a Special Economic Zone and whether the assessment could be revised on that basis.

Analysis: The statutory exemption for inter-State sales to a Special Economic Zone unit is traceable to Section 8(6) of the Central Sales Tax Act, 1956. The Court held that the principle recognised in the earlier Division Bench decision, that forms produced after assessment may be considered and the assessment revised subject to scrutiny, was not confined to Form C or to concessional-rate transactions. The distinction between concession and exemption was found to be immaterial on the facts, and the authority's summary rejection of the precedent without reasons was held unsustainable. The petitioner had already sought rectification through the relevant statutory route under Section 84 of the Tamil Nadu Value Added Tax Act, 2006 read with Section 9(2) of the Central Sales Tax Act, 1956.

Conclusion: The Form I submitted after assessment had to be examined, and the assessment could be revised if warranted; the impugned order refusing to do so was set aside.

Final Conclusion: The writ petition succeeded, and the assessing authority was directed to reconsider the post-assessment Form I and complete a fresh assessment in accordance with law.

Ratio Decidendi: A statutory exemption claim supported by a form produced after assessment can be considered and the assessment revised, provided the form is scrutinised and the applicable precedent is followed.

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