C declaration forms must be issued once statutory eligibility is met; authorities cannot insist on a merits enquiry.

At the stage of issuing C declaration forms for inter-State purchases, the authority's scrutiny is confined to statutory eligibility conditions: the applicant must be a registered dealer, the goods must fall within the registration, and the prescribed requirements must be met. It cannot withhold the forms on the basis of a further merits enquiry into the underlying transactions. As the record showed no allegation of short payment of tax, suppression, or misstatement of goods, the refusal to issue the forms was unjustified and the petitioner was entitled to the C forms sought.

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Issues: Whether the respondents were bound to issue the petitioner the required C declaration forms for inter-State purchases and whether such issuance could be withheld on the ground of a further enquiry into the transactions.

Analysis: The petitioner was a registered dealer and the materials on record did not disclose any allegation of short payment of tax or suppression or misstatement of goods. The authorities relied on an internal circular to justify disabling the online facility and insisted on additional verification. The governing legal position, however, is that at the stage of issuance of C forms the authority is not required to conduct a detailed enquiry into the underlying transactions. The relevant enquiry is limited to whether the applicant is a registered dealer, the goods are covered by the registration, and the prescribed requirements for issuance have been satisfied. The prior decision relied on by the Court, followed by other High Courts, supports the view that once those conditions are met, the forms have to be issued.

Conclusion: The refusal to issue C forms was not justified and the respondents were directed to issue the 17 C forms to the petitioner.

Final Conclusion: The writ petition succeeded and the petitioner obtained the relief sought for issuance of C declaration forms.

Ratio Decidendi: At the stage of issuing C declaration forms, the authority's scrutiny is confined to the statutory eligibility conditions and it cannot deny the forms by undertaking a merits enquiry into the nature of the underlying inter-State transactions.

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