JUDGMENT

B.P. Jeevan Reddy, J.-These appeals are preferred against the judgment of a Division Bench of the Rajasthan High Court allowing a batch of special appeals filed by the respondents-assessees. The special appeals were preferred against the common judgment of a learned Single Judge of that Court dismissing the writ petitions filed by them. The matter arises under the Central Sales Tax Act, 1956.

2. The respondents-assessees are manufacturers and/or dealers in edible oils and stainless steel sheets. During the relevant years, they effected a large number of inter-State sales to various dealers in Bombay and Gujarat. They obtained C-forms from the purchasing dealers and submitted them in their assessment proceedings. On survey and inquiry, it was found that many of the C-forms were either not valid or not genuine. Some of them were found to have been issued to dealers other than the respondents. Accordingly, anti-evasion proceedings were commenced against the respondents. Notices were issued calling upon them to show-cause why additional tax and penalty be not levied and recovered from them. It is at that stage that the respondents approached the Rajasthan High Court by