STATE OF RAJASTHAN & ORS.versusCOMBINED TRADERS

                  [2025] 4 S.C.R. 816 : 2025 INSC 496

                        State of Rajasthan & Ors.
                                    v.
                           Combined Traders
                       (Civil Appeal No. 1208 of 2025)
                                  16 April 2025
                [Abhay S. Oka* and Ujjal Bhuyan, JJ.]


                            Issue for Consideration
       Sub-rule (20) of Rule 17 of the Central Sales Tax (Rajasthan) Rules,
       1957 provided that where any dealer had generated declaration
       forms or certificates by misrepresentation of fact or by fraud or in
       contravention of the provisions of the Central Sales Tax Act, 1956
       [CST Act] and rules made thereunder, the assessing authority or
       any other authority authorised by the Commissioner after affording
       such dealer an opportunity of being heard, is empowered to cancel
       such declaration forms or certificates. By the impugned judgment,
       the High Court held that the first appellant-State had no rule-making
       power to frame a rule providing for the cancellation of validly issued
       declarations/forms. The High Court held that sub-rule (20) of Rule
       17 of the Rajasthan Rules was ultra vires Sections 8(4), 13(1)
       (d), 13(3) and 13(4)(e) of the CST Act. The validity of sub-rule 20
       of rule 17 of the Central Sales Tax (Rajasthan) Rules, 1957 was
       therefore in issue before this Court.

                                   Headnotes†
       Central Sales Tax (Rajasthan) Rules, 1957 – Sub-rule (20) of
       Rule 17 – Central Sales Tax Act, 1956 – ss.8(4), 13(1)(d), 13(3)
       and 13(4)(e) – High Court held that sub-rule (20) of Rule 17
       of the Rajasthan Rules was ultra vires ss.8(4), 13(1)(d), 13(3)
       and 13(4)(e) of the CST Act – Correctness of:
       Held: The Central Government has the rule-making power to
       prescribe the form of declaration and lay down particulars to be
       contained in any declaration – Therefore, the form of declaration
       under Section 8(4) of the Central Sales Tax Act, 1956 and the
       contents thereof are to be provided by the rules framed by the
       Central Government in accordance with Section 13(1)(d) of the CST
       Act – If the State Government exercises the rule-making power

* Author
[2025] 4 S.C.R.                                                           817

             State of Rajasthan & Ors. v. Combined Traders


     under sub-section (3) of Section 13 by making rules providing for
     cancellation of a declaration in Form C as provided in Central
     Registration Rules, the State Rules will be inconsistent with the
     Central Registration Rules framed by the Central Government in
     exercise of power under Section 13(1)(d) of the CST Act – The
     State Government cannot frame rules in exercise of power under
     Section 13(3) which will be inconsistent with the rules framed by
     the Central Government in exercise of powers under Section 13(1)
     of the CST Act. No fault with the view taken by the High Court that
     sub-rule (20) of Rule 17 of the Rajasthan Rules is inconsistent
     with the Central Registration Rules framed in exercise of power
     under clause (d) of sub-section (1) of Section 13 of the CST Act.
     [Paras 12.1, 16, 18]

                             Case Law Cited
     The State of Madras v. R Nand Lal & Co. [1967] 3 SCR 645 :
     (1967) (20) STC 374 (SC) : 1968 SCC OnLine SC 142 – relied on.
     Sales Tax Officer, Ponkunnam & Anr. v. K.I. Abraham [1967]
     3 SCR 518 : (1967) (20) STC 367 (SC) : 1967 SCC OnLine
     SC 157 – referred to.
     Jain Manufacturing (India) Pvt Ltd v. Commissioner of Value Added
     Tax & Anr. (2016) (93) VST (326) (Delhi) : 2016 SCC OnLine
     Del 3656 – referred to.

                                List of Acts
     Central Sales Tax (Rajasthan) Rules, 1957; Central Sales Tax
     Act, 1956.

                             List of Keywords
     Sub-rule (20) of Rule 17 of Central Sales Tax (Rajasthan) Rules,
     1957; Dealer; Declaration forms or certificates; Rule-making
     power; Cancellation of validly issued declarations/forms; Central
     Registration Rules; State Rules.

                            Case Arising From
     CIVIL APPELLATE JURISDICTION: Civil Appeal No. 1208 of 2025
     From the Judgment and Order dated 01.05.2019 of the High Court
     of Judicature for Rajasthan at Jaipur in DBCWP No. 11580 of 2018
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                            Appearances for Parties
       Advs. for the Appellants:
       Dr. Manish Singhvi, Sr. Adv., Irshad Ahmad.
       Advs. for the Respondent:
       Rajesh Jain, Virag Tiwari, Rishabh Jain, Ramashish, Ms. Tanya
       Saraswat, Avadh Bihari Kaushik.

                   Judgment / Order of the Supreme Court

                                     Judgment

       Abhay S. Oka, J.

1.     The first appellant is the State of Rajasthan. A writ petition was filed before
       the High Court of Judicature for Rajasthan by the respondent-Combined
       Traders invoking jurisdiction of the High Court under Article 226 of
       the Constitution of India for challenging the validity of sub-rule (20) of
       rule 17 of the Central Sales Tax (Rajasthan) Rules, 1957 (for short,
       ‘the Rajasthan Rules’). Sub-rule (20) of Rule 17 was incorporated by
       way of an amendment with effect from 14th July 2014. Sub-rule (20)
       of Rule 17 provided that where any dealer had generated declaration
       forms or certificates by misrepresentation of fact or by fraud or in
       contravention of the provisions of the Central Sales Tax Act, 1956
       (for short, ‘the CST Act’) and rules made thereunder, the assessing
       authority or any other authority authorised by the Commissioner after
       affording such dealer an opportunity of being heard, is empowered
       to cancel such declaration forms or certificates. By the impugned
       judgment, the High Court held that the first appellant-State had no
       rule-making power to frame a rule providing for the cancellation of
       validly issued declarations/forms. The High Court held that sub-rule
       (20) of Rule 17 of the Rajasthan Rules was ultra vires Sections 8(4),
       13(1)(d), 13(3) and 13(4)(e) of the CST Act.
2.     During 2017-18, the respondent sold certain goods to M/s. H.G.
       International and M/s. Saraswati Enterprises (originally respondent
       Nos.2 and 3, whose names were deleted from the array of parties)
       against Form C amounting to Rs. 4.89 crores and Rs. 7.20 crores
       respectively. Goods were sold in the first quarter of the year 2017-18.
3.     The revenue authorities inspected the places of business of M/s. H.G.
       International and M/s. Saraswati Enterprises. On inspection, it was
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             State of Rajasthan & Ors. v. Combined Traders


     revealed that no business activity was carried out at the places and
     registration of M/s. H.G. International and M/s. Saraswati Enterprises
     was completely bogus. Notices were issued to the respondent for
     the cancellation of Form C. To claim reduced rates of taxes as per
     Section 8(1) of the CST Act, the respondent had furnished Form C as
     required by Section 8(4) of the CST Act. A single Form C is required
     to be submitted for a quarter as provided in the second proviso to
     sub-rule (1) of Rule 12 of the Central Sales Tax (Registration and
     Turnover) Rules, 1957 (for short, ‘the Central Registration Rules’).
4.   M/s. H.G. International and M/s. Saraswati Enterprises obtained
     Form C online on 6th July 2017. The respondent claimed a refund
     in the return filed on 11th July 2017 for the first quarter of 2017-2018
     under the Delhi Value Added Tax Act, 2004 (for short, ‘the Delhi VAT
     Act’). The refund was not given within two months of the return filing
     date. Therefore, the respondent filed a writ petition before the Delhi
     High Court. By the order dated 18th September 2017, the Delhi High
     Court directed the authorities in Delhi to refund the amount along
     with due interest.
5.   By separate orders dated 7th December 2017, the third appellant
     cancelled the declaration forms of M/s. H.G. International and M/s.
     Saraswati Enterprises on the ground that they were not found
     functioning at their respective business premises. The declaration
     forms were cancelled, exercising power under sub-rule (20) of
     Rule 17 of the Rajasthan Rules read with Sections 48 and 16(4)
     of the Rajasthan Value Added Tax Act, 2003. Even the registration
     certificates of the said firms were cancelled. Before the said order, the
     third appellant issued letters dated 20th and 30th November 2017 to
     VATO Ward-17, New Delhi, informing about the cancellation of Form
     C of the two entities. The respondent filed a writ petition before the
     High Court of Rajasthan, Bench at Jaipur. As stated earlier, the first
     prayer was for declaring sub-rule (20) of Rule 17 of the Rajasthan
     Rules as ultra vires Sections 8(4), 13(1)(d), 13(3) and 13(4)(e) of the
     CST Act. Consequential prayers were made for challenging the order
     dated 7th December 2017 and the communications of 20th and 30th
     November 2017. Other consequential reliefs were also prayed for.

     SUBMISSIONS
6.   The learned senior counsel appearing for the appellants has taken
     us through the relevant provisions of the CST Act and the Rajasthan
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       Rules. The learned senior counsel invited our attention to the rule-
       making power conferred by Section 13 (3) of the CST Act. He pointed
       out that the general rule-making power has been conferred on the
       State Government to make rules which are not inconsistent with
       the provisions of the CST Act and the rules made by the Central
       Government under Section 13(1) thereof. He submitted that sub-
       rule (20) of Rule 17 of the Rajasthan Rules is not inconsistent with
       the provisions of the CST Act. He submitted that sub-rule (20) of
       Rule 17 has been enacted to prevent fraud and contravention of the
       provisions of the CST Act and rules made thereunder. He submitted
       that sub-section (3) of Section 13 of the CST Act confers a power
       on the State Government to make rules to carry out the purposes of
       the CST Act. Rule-making power can be exercised under sub-section
       (3) of Section 13 to check evasion. He submitted that the activity of
       preventing evasion is for carrying out the purposes of the CST Act.
7.     The learned counsel invited our attention to the separate orders dated
       7th December 2017 passed by the Commercial Tax Officer of the
       first appellant-State Government, by which Forms C issued to M/s.
       H.G. International and M/s. Saraswati Enterprises were cancelled
       and consequently, their registration certificates were also cancelled.
       He pointed out that a finding was recorded that on inspection of the
       premises of M/s. H.G. International and M/s. Saraswati Enterprises,
       it was found that no commercial activity or business was being
       carried out. Therefore, it was observed that the commercial activity
       of M/s. H.G. International and M/s. Saraswati Enterprises was
       doubtful. M/s. H.G. International and M/s. Saraswati Enterprises
       did not appear notwithstanding service of notice. Therefore, on the
       ground of pleading false facts, the declaration forms (Form C) were
       ordered to be cancelled. He submitted that there is no inconsistency
       between sub-rule (20) of Rule 17 of the Rajasthan Rules and any
       of the provisions of the CST Act or the rules framed thereunder by
       the Central Government.
8.     The learned counsel appearing for the respondent invited our
       attention to Section 13 of the CST Act. He pointed out that the
       rule-making power under clause (d) of sub-section (1) of Section
       13 has been conferred on the Central Government, providing for
       prescribing a form setting out all the particulars to be contained in
       any declaration or certificate to be given under the CST Act. He
       submitted that clause (d) does not confer any power on the Central
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                 State of Rajasthan & Ors. v. Combined Traders


      Government to make rules to cancel any declaration or certificate
      under the CST Act. In any event, no such rules have been framed
      by the Central Government. Inviting our attention to sub-section (4)
      of Section 13, he submitted that none of the clauses (a) to (g) confer
      any power on the State Government to frame rules, providing for
      cancellation of declarations and certificates under the CST Act. He
      invited our attention to Section 8 (1) of the CST Act, which provides
      for a dealer selling the goods, furnishing to the prescribed authority,
      a declaration duly filled and signed by a registered dealer to whom
      the goods are sold. He submitted that Section 8 does not provide for
      cancellation of the declaration. He invited our attention to Section 7
      of the CST Act, which provides for registration of dealers. He pointed
      out that sub-section (5) of Section 7 specifically confers a power on
      the authority to cancel the registration certificate. Such provision is
      absent in Section 8 of the CST Act.
9.    The learned counsel submitted that sub-rule (20) of Rule 17 is a
      standalone rule which was introduced on 14th July 2014 after a gap
      of 57 years from the date on which the CST Act came into force.
      He submitted that no other State has made any such rule. He
      relied upon a decision of the Delhi High Court in the case of Jain
      Manufacturing (India) Pvt Ltd v. Commissioner of Value Added
      Tax & Anr.1 In this case, the Commissioner under the Delhi VAT Act
      had cancelled Form C. He pointed out that the counsel appearing
      for the Commissioner stated that there was no provision in the CST
      Act for cancellation of Form C. He submitted that the special leave
      petition preferred against the decision was dismissed on the ground
      of low tax effect.
10. The learned counsel relied upon a decision of this Court in the case
    of Sales Tax Officer, Ponkunnam & Anr. v. K.I. Abraham.2 He
    also relied upon another decision of this Court in the case of The
    State of Madras v. R Nand Lal & Co.3 He would therefore submit
    that the view taken by the High Court of Rajasthan in the impugned
    judgment is correct.




1    (2016) (93) VST (326) (Delhi) : 2016 SCC OnLine Del 3656
2    (1967) (20) STC 367 (SC) : 1967 SCC OnLine SC 157
3    (1967) (20) STC 374 (SC) : 1968 SCC OnLine SC 142
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       CONSIDERATION OF SUBMISSIONS
11. Firstly, we must advert to Section 8 of the CST Act. Sub-sections
    (1) and (4) of Section 8 as it stood at the relevant time, read thus:
          “8. Rates of tax on sales in the course of inter-State
          trade or commerce- (1) Every dealer, who in the course
          of inter-State trade or commerce-
                  (a) sells to the Government any goods; or
                  (b) sells to a registered dealer other than the
                  Government goods of the description referred to in
                  sub-section (3),
          shall be liable to pay tax under this Act, with effect from
          such date as may be notified by the Central Government
          in the Official Gazette for the purpose, which shall be two
          per cent of this turnover or at the rate applicable to the
          sale or purchase of such goods inside the appropriate
          State under the sales tax law of that State, or, as the case
          may be, under any enactment of that State imposing value
          added tax, whichever is lower:
          Provided that the rate of tax payable under this sub-
          section by a dealer shall continue to be four per cent of
          his turnover, until the rate of two per cent, takes effect
          under this sub-section.”
          .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. ..
          (4) The provisions of sub-section (1) shall not apply to
          any sale in the course of inter-State trade or commerce
          unless the dealer selling the goods furnishes to the
          prescribed authority in the prescribed manner-
          (a) a declaration duly filled and signed by the registered
          dealer to whom the goods are sold containing the
          prescribed particulars in a prescribed form obtained
          from the prescribed authority; or
          (b) if the goods are sold to the Government, not being
          a registered dealer, a certificate in the prescribed form
          duly filled and signed by a duly authorised officer of the
          Government:
[2025] 4 S.C.R.                                                                                        823

             State of Rajasthan & Ors. v. Combined Traders


            Provided that the declaration referred to in clause (a) is
            furnished within the prescribed time or within such further
            time as that authority may, for sufficient cause, permit.”
                                                                       (emphasis added)

     11.1. Sub-section (1) of Section 8 provides that, a dealer who in
           the course of inter-State trade or commerce sells goods of
           the description provided under sub-section (3) to a registered
           dealer, shall be liable to pay tax which shall be 2 % of his
           turnover or at the rate applicable to the sale and purchase of
           such goods inside the appropriate State under the sales tax
           law of that State, whichever is lower. In view of sub-section
           (4) of Section 8, the condition precedent for applicability of
           sub-section (1) is that the dealer selling the goods in the
           course of inter-State trade or commerce must furnish to the
           prescribed authority in the prescribed manner a declaration
           duly filled containing the prescribed particulars in a prescribed
           form obtained from the prescribed authority and signed by the
           registered dealer to whom the goods are sold.
12. The word “prescribed” means prescribed by the rules. Under sub-
    section (1) of Section 13, the rule making power has been conferred
    on the Central Government providing for what is set out in clauses
    (a) to (g) of Section 13(1). Clause (d) of Section 13(1) thereof is
    material, which reads thus:
            “13. Power to make rules-
            (1) The Central Government may, by notification in the
            Official Gazette, make rules providing for –
            .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. ..
            (d) the form in which and the particulars to be contained
            in any declaration or certificate to be given under this
            Act the State of origin of such form or certificate
            and the time within which any such certificate or
            declaration shall be produced or furnished;”
                                                                       (emphasis added)

     12.1. Thus, the Central Government has the rule-making power
           to prescribe the form of declaration and lay down particulars
824                                                                               [2025] 4 S.C.R.

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           to be contained in any declaration. Therefore, the form of
           declaration under Section 8(4) and the contents thereof are to
           be provided by the rules framed by the Central Government
           in accordance with Section 13(1)(d) of the CST Act.
13. Now, we come to sub-sections (3) and (4) of Section 13 of the CST
    Act, which read thus:
         “13. Power to make rules-
         .. .. .. .. .. .. .. .. .. .. .. .. .. .. . .. .. .. .. .. .. .. .. .. .. .. . .. .. .. .
         (3) The State Government may make rules, not
         inconsistent with the provisions of this Act and the
         rules made under sub-section (1), to carry out the
         purpose of this Act.
         (4) In particular and without prejudice to the powers
         conferred by sub-section (3), the State Government may
         make rules for all or any of the following purposes, namely:-
         (a) the publication of lists of registered dealers, of the
         amendments made in such lists from time to time, and
         the particulars to be contained in such lists;
         (aa) the manner in which security may be furnished under
         sub-section (2A) or sub-section (3A) or sub-section (3C)
         of section 7 and the manner in which and the time within
         which any deficiency may be made up under sub-section
         (3E) of that section;
         (b) the form and manner in which accounts relating to
         sales in the course of inter-State trade or commerce shall
         be kept by registered dealers;
         (c) the furnishing of any information relating to the stocks
         of goods of purchases, sales and deliveries of books by,
         any dealer or any other information relating to his business
         as may be necessary for the purposes of this Act;
         (d) the inspection of any books, accounts or documents
         required to be kept under this Act, the entry into any
         premises at all reasonable times for the purposes of
         searching for any such books, accounts or documents
         kept or suspected to be kept in such premises and the
         seizure of such books, accounts or documents;
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             State of Rajasthan & Ors. v. Combined Traders


            (e) the authority from whom, the conditions subject to
            which and fees subject to payment of which any form of
            certificate prescribed under clause (a) of the first proviso
            to sub-section (2) of section 6 or of declaration prescribed
            under sub-section (1) of section 6A or subsection (4) of
            section 8 may be obtained, the manner in which such
            forms shall be kept in custody and records relating thereto
            maintained and the manner in which any such form may
            be used and any such certificate or declaration may be
            furnished;
            (ee) the form and manner in which, and the authority to
            whom, an appeal may be preferred under sub-section
            (3H) of section 7, the procedure to be followed in hearing
            such appeals and the fees payable in respect of such
            appeals;
            (f) in the case of an Undivided Hindu Family, association,
            club, society, firm or company or in the case of a person
            who carries on business as a guardian or trustee or
            otherwise on behalf of another person, the furnishing of
            a declaration stating the name of the person who shall
            be deemed to be the manager in relation to the business
            of the dealer in the State and the form in which such
            declaration may be given;
            (g) the time within which, the manner in which and the
            authorities to whom any change in the ownership of any
            business or in the name, place or nature of any business
            carried on by any dealer shall be furnished.”
                                                    (emphasis added)

     13.1. On the face of it, none of the clauses (a) to (j) of sub-section
           (4) empower the State Government to frame rules providing
           for cancellation of declarations or forms furnished as per the
           rules framed by the Central Government in accordance with
           clause (d) of sub-section (1) of Section 13 of the CST Act.
14. In exercise of the rule-making power under clause (d) of sub-section (1)
    of Section 13, the Central Registration Rules have been framed. Rule
    12(1) provides that the declaration referred to in sub-section (4) of
    Section 8 of the CST Act shall be in Form C prescribed thereunder.
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       Therefore, the Central Registration Rules have laid down the form
       of declaration referred to in Section 8(4). A perusal of the Central
       Registration Rules shows that no power is conferred on any authority
       to cancel the declaration in Form C. Thus, the rules which prescribe
       the form of declaration in terms of Section 8(4), do not provide
       for cancellation of the declaration on the ground that commercial
       activities were not found at the address mentioned in the declaration.
       There is no provision in the Central Registration Rules to cancel the
       declaration in Form C. In contrast, the Central Registration Rules
       provide for cancellation of the certificate of registration for giving
       effect to sub-section (5) of Section 7 of the CST Act.
15. Now, coming back to sub-sections (3) and (4) of Section 13, the rule-
    making power conferred on the State Government under sub-section
    (4) is for any or all of the specific purposes laid down in clauses (a)
    to (j). As stated earlier, none of these clauses provide for making a
    rule to enable the authorities to cancel a declaration in Form C. It is
    true that under sub-section (3) of Section 13, the State Government
    has power to frame rules to carry out purposes of the CST Act.
    However, power of sub-section (3) is circumscribed by its first part
    which provides that the rules made to carry out the purposes of the
    CST Act should not be inconsistent with the provisions of the CST
    Act and the rules made by the Central Government in exercise of
    powers under Section 13(1) of the CST Act.
16. A specific rule-making power under clause (d) of sub-section (1)
    of Section 13 has been exercised by the Central Government
    by framing the Central Registration Rules laying down the form
    of declaration (Form C) required to be furnished in terms of sub-
    section (4) of Section 8. As stated earlier, the Central Registration
    Rules do not vest power in any authority to cancel the declaration
    in Form C. Therefore, if the State Government exercises the rule-
    making power under sub-section (3) of Section 13 by making rules
    providing for cancellation of a declaration in Form C as provided in
    Central Registration Rules, the State Rules will be inconsistent with
    the Central Registration Rules framed by the Central Government
    in exercise of power under Section 13(1)(d) of the CST Act. The
    State Government cannot frame rules in exercise of power under
    Section 13(3) which will be inconsistent with the rules framed by
    the Central Government in exercise of powers under Section 13(1)
    of the CST Act.
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              State of Rajasthan & Ors. v. Combined Traders


17. The respondent relied upon the decision of this Court in the case of
    R. Nand Lal & Co3. In the facts of this case, the assessing authority
    declined to assess the turnover as prescribed by sub-section (1) of
    Section 8 of the CST Act on the ground that the declaration in Form
    C covered two or three transactions contrary to the first proviso to
    Rule 10(1) of the Rules framed by the State Government under the
    CST Act. This Court, in the said decision, while dealing with the
    rule-making power of the State under Section 13, held thus:
           “.. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. ..
           We are constrained to observe that the rule-making
           authorities have failed to appreciate the scheme of Section
           13 of the Central Sales Tax Act. We are of the opinion that
           it was not within the competence of the State authorities
           under Section 13(3) and (4) of the Central Sales Tax
           Act to provide that a single declaration covering more
           than one transaction shall not be made. Authority to
           prescribe such an injunction cannot have its source
           in Section 13(3) or Section 13(4)(e); it can only be in
           the authority conferred by clause (d) of Section 13(1)
           by the Central Government. The Central Government
           has, in exercise of the power under Section 13(1)(d)
           prescribed that form of declaration and the particulars
           to be contained in the declaration. A direction that
           there shall be a separate declaration in respect of each
           individual transaction may appropriately be made in
           exercise of the power conferred under Section 13(1)
           (d). The State Government is undoubtedly empowered
           to make under sub-section (3) and (4) of Section 13;
           but the rules made by the State Government must
           not be inconsistent with the provisions of the Act and
           the Rules made under sub-section (1) of Section 13
           to carry out the purposes of the Act. If the authority
           to make a Rule prescribing that the declaration shall not
           contain more than one transaction can be made only under
           Section 13(1)(d), the State Government cannot exercise
           that authority.
           .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. ..”
                                                                        (emphasis added)
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18. Therefore, for the reasons set out above, it is not possible to find fault
    with the view taken by the High Court that sub-rule (20) of Rule 17
    of the Rajasthan Rules is inconsistent with the Central Registration
    Rules framed in exercise of power under clause (d) of sub-section (1)
    of Section 13 of the CST Act.
19. Hence, the appeal must fail and the same is dismissed with no order
    regarding costs.

       Result of the case: Appeal dismissed.




       †
           Headnotes prepared by: Bibhuti Bhushan Bose