DR. A. S. ANAND, C.J.

The respondents are dealers in rice mill spare parts and accessories. They were registered under the Central Sales Tax Act. During the verification of the accounts by the assessing authority, it transpired that the assessees had purchased oil engine spares from outside the State on concessional rate of tax by issuing "C" forms during the assessment years 1975-76, 1976-77, 1977-78, 1978-79 and 1979-80. The assessing authority was of the opinion that the registration certificate issued to the assessees did not enable them to issue "C" form certificates to purchase from outside the State at concessional rate of tax "oil engine spares" and, therefore the issue of "C" form certificate by the assessees was based on a false representation that they were entitled to purchase oil engine spares also on the basis of the registration certificate issued to them. The assessing authority invoked the provisions of section10A of the Central Sales Tax Act, and after following the procedure prescribed by law, levied penalty, holding that the assessees had committed an offence under section10(b) of the Act. The assessees went up in appeal before the appellate authority