YASHWANT VARMA,J. - (1.) Heard learned counsel for the revisionist and the learned Standing Counsel for the State-respondents.
(2.) This revision which emanates from Appeal No. 472 of 1996 relating to an assessment under CST 1956 for the Assessment Year 1987-88 has been preferred asserting that the following questions of law arise from the order of the Tribunal: "(i). Whether, on the facts and in the circumstances of the case, the Tribunal was legally justified in rejecting the books of account? (ii). Whether, on the facts and in the circumstances, the Tribunal was justified in holding the purchases on behalf of Ex.U.P.Principal as inter-state-sales liable to Central Sales? (iii). Whether, on the facts and in the cirumstances of the case, the Tribunal was legally justified in affirming the order of the authorities below wherein central sales has been levied in absence of Form-F? (iv). Whether, on the facts and in the circumstances of the case, the Tribunal was legally justified in upholding the levy of tax on "Bardana"?"
(3.) The primary submission of Sri Agarwal, learned counsel for the revisionist was that the assessing authority has merely on the basis of a few transactions proceeded to disbelieve the stand taken by the assessee that it was acting on behalf of the ex-U.P. principals and that the dispatches were exempt from tax being an inter-State dispatch made for and on behalf of ex-U.P. principals. The submission was that unless each and every transaction had been independently scrutinized, the assessing authority could not have held the revisionist liable to tax.;