RAMANUJAM J.

The respondents in all the four cases are the same and they were assessees under the Central Sales Tax Act, 1956. For the assessment years 1958-59 to 1961-62, it was found that they had purchased motor spare parts on the basis of the 'C' form certificate issued to them under the provisions of the Central Sales Tax Act for sale, but instead of selling them, they used them for their own consumption. The revenue proceeded on the basis that since the goods purchased were not used for he purpose specified in section 8(3)(b) and as recorded in the 'C' form certificate, the assessee has committed an offence under section 10(d) of the Act in that he has used the goods purchased by him on the basis of the 'C' form certificate for a purpose other than the one mentioned therein and, therefore, they are liable to penalty as well. All the authorities below, including the Tribunal, have found that the assessee has actually committed the offence under section 10(d) in using the goods for a purpose other than the one mentioned in the 'C' form certificate. Being a finding of fact, we have to accept the same and proceed on the basis that the assessees have committed the offen