SRINIVASAN, J.

Out of the turnover of Rs. 53, 742 returned by the assessee-respondent, Rs. 34, 560 was covered by C Forms. The balance of the turnover was not covered by C Forms and the assessing authority, the Deputy Commercial Tax Officer, accordingly assessed this latter part of the turnover at seven per cent. under the Central Sales Tax Act. An appeal was taken by the assessee to the Appellate Assistant Commissioner, before whom the assessee admitted that the C Forms relevant to the turnover of Rs. 19, 000 and odd assessed at seven per cent. had been received only after the final assessment was over. The final assessment by the Deputy Commercial Tax Officer in this case was on 15th June, 1960, and the relevant forms were produced before the Appellate Assistant Commissioner on 27th July, 1960. No explanation was given before the appellate authority for failure to produce these C Forms earlier. The Appellate Assistant Commissioner therefore took the view that the transactions covered by this turnover of Rs. 19, 000 and odd had to be treated as sales made to unregistered dealers and confirmed the levy of tax on this turnover at seven per cent.

On further appeal to the Tr