RAMANUJAM, J.

This is an appeal filed against the order of the Board of Revenue cancelling the order passed by the Appellate Assistant Commissioner and restoring the order of the assessing authority levying a penalty of Rs. 12, 579 under section 10A of the Central Sales Tax Act. The assessees are manufacturers of textile machinery. They had imported asbestos sheets worth Rs. 96, 756.65 from outside the State and had issued C forms in respect of the said purchase of asbestos sheets. The assessing authority took the view that the registration certificate issued to the assessees by the registering authority constituted under that Act did not enable them to issue C form certificates in respect of asbestos sheets and that the issue of C form certificates by the assessees was under a misrepresentation that they are entitled to purchase asbestos sheets under the registration certificates issued to them. He, therefore, invoked the provisions of section 10A and levied the penalty holding that the assessees have committed an offence under section 10(b) of the Act.

There was an appeal by the assessees to the Appellate Assistant Commissioner, who set aside the order holding that for