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Issues: Whether the plaintiff proved the disputed invoices, debit notes and ST-1 forms and whether the defendants discharged the burden of establishing that the transactions were fictitious, fraudulent or obtained under duress.
Analysis: The invoices, debit notes and ST-1 forms were stamped and signed by the defendants' authorised representatives, and the defendants' own witness admitted signatures on those documents. The claim that the documents were executed under duress was unsupported by any complaint or independent evidence. The documents were maintained in the ordinary course of business and were sufficient to establish the sales and the corresponding liability. The defendants, having alleged that the transactions were sham and fraudulent, carried the burden of proving that plea and failed to do so. The appellant's registration as a dealer and the statutory scheme permitting deduction on sales to a registered dealer under the Delhi sales tax law also supported the genuineness of the transactions.
Conclusion: The issue was decided in favour of the plaintiff. The transactions were held to be genuine and the defence of fraud, fictitious billing and duress was rejected.
Final Conclusion: The High Court's reversal of the trial court was set aside and the plaintiff's money claim was restored with interest.
Ratio Decidendi: Where commercial invoices and statutory declaration forms are admitted or proved by signatures of the buyer's authorised representative, a plea that the underlying sales were sham or executed under duress must be proved by the party alleging it, and failure to do so permits recovery on the basis of the documentary record.