These three revision petitions were decided by a common order dated October 8, 1984, and were dismissed. The question was whether certain purchases were made by the dealer in the course of inter-State trade or commerce. The Tribunal had held that the purchases were made on behalf of ex-U. P. principal in the course of inter-State trade or commerce. The revision petitions were dismissed following the judgment of this Court in Commissioner of Sales Tax v. Girdhari Lal Gomti Prasad (1984) 2 UPTC 914. In making the aforesaid purchases the dealer had issued form IIIC to the seller certifying that it had purchased the goods in question. By the U. P. Sales Tax (Amendment and Validation) (Second) Ordinance, 1990, section 12-A of the Act was amended by enacting sub-section (2) as under :

" (2) Where any dealer claims that he is not liable to tax under section 3-D in respect of any transaction of purchases -

(a) any declaration made or certificate issued by him admitting to be the first purchaser and accepting the liability to pay purchase tax, shall be conclusive evidence of his liability to pay the purchase tax in respect of the transaction specified in such declarati