C-Form entitlement may be scrutinised before issuance when eligibility is disputed, subject to hearing and independent decision-making.

Where entitlement to C-Forms is prima facie disputed, the sales tax authority may examine eligibility before issuing the forms and is not required to grant them mechanically first and inquire later. The authority must, however, hear the dealer, decide the claim independently, and act expeditiously. A refusal communicated without a proper speaking order was unsustainable, but the core principle is that threshold scrutiny of entitlement is permissible when the claim itself is doubted. The decision must not be based on a superior officer's prima facie view in an affidavit.

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Issues: Whether the authority was bound to issue C-Forms first and postpone scrutiny of eligibility, or could examine the dealer's claim to entitlement before issuance of the C-Forms.

Analysis: The communication refusing C-Forms was found unsustainable as a speaking order, but the matter turned on whether the dealer's claim to be engaged in mining activities was prima facie acceptable. Where the claim itself is doubted at the threshold, the sales tax authority is not required to issue C-Forms mechanically and only thereafter undertake inquiry. The authority may first examine eligibility, but it must do so promptly and after hearing the dealer. The decision must be taken independently and not on the basis of any superior officer's prima facie view in an affidavit.

Conclusion: The authority was permitted to decide eligibility before issuance of C-Forms, subject to hearing the dealer and deciding the claim independently and expeditiously.

Ratio Decidendi: When entitlement to a statutory form is prima facie disputed, the authority may determine eligibility before issuance rather than issue the form as a matter of course, provided the affected party is heard and the decision is taken independently.

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