Judgment :- RAMAKRISHNAN, J. The assessee is a registered dealer in wool at Vaniyambadi. Out of his turnover in 1959-60, the sum in dispute before us is Rs. 2, 08, 343-45 nP. which represents the sales effected to registered purchasing dealers in Punjab. On the ground that the C Forms supplied by the purchasing dealers in the Punjab, and filed by the assessee for the inter-State sales effected by him, did not comply with the rules, he was assessed at 7 per cent. on these sales and was denied the benefit of assessment at the lower rate of 1 per cent. The specific ground on which the benefit of lower rate of assessment was denied was that the C Form contravened rule 10(1) of the rules framed by the Madras State under the Central Sales Tax Act. The rule states that no single declaration shall cover more than one transaction of sale. Apparently the Punjab purchasing dealers gave C Forms in which they have included all the purchases effected by them from the Madras dealer during the year of assessment. The appeal to the Appellate Assistant Commissioner as well as to the Appellate Tribunal failed and the assessee has come before this Court in revision. Learned counsel for the petitioner-assessee urged that the registered dealers in Punjab who gave C Forms to the assessee had complied with the rule in force in Punjab framed by the Punjab State Government. There is no rule in Punjab corresponding to the Madras rule requiring a separate C Form for each sale. According to the learned counsel, rule 10 of the Madras rules would apply to registered purchasing dealers in Madras and will not bind the registered purchasing dealers in Punjab. Therefore, it was contended that the denial to the assessee of the benefit of the lower rate of assessment was improper.We shall briefly refer to the provisions in the Central Sales Tax Act in regard to C Forms. Section 8(1)(b) of the Act states that every dealer, who, in the course of inter-State trade or commerce, 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 the Act which shall be one per cent. of his turnover. Section 8(1)(b) of the Act states that every dealer, who, in the course of inter-State trade or commerce, 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 the Act which shall be one per cent. of his turnover. Section 8(4) states that 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 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. The several prescriptions mentioned in this section have been made by rules framed partly by the Central Government and partly by the appropriate State Governments. Section 13(1)(d) gives power to the Central Government to frame rules providing for the form in which and the particulars to be contained, in any declaration or certificate to be given under the Act. Section 13(4)(e) gives the State Government power to make rules providing for the authorities from whom, the conditions subject to which, and the fees subject to payment of which, any form of declaration prescribed under sub-section (4) of section 8 may be obtained, the manner in which the form shall be kept in custody and records relating thereto maintained, the manner in which any such form may be used and any such declaration may be furnished. In pursuance of the power under section 13(1)(d), the Central Government framed rule 12 which states that the declaration and the certificate under section 8(4) shall be in Forms C and D respectively. This takes us to Form C which is prescribed by the Central Government. This form should be in counterfoil, duplicate and original. The counterfoil is to be retained by the purchasing dealer, the duplicate by the selling dealer and the original is to be furnished to the prescribed authority in accordance with the rules framed under section 13(4)(e) by the appropriate State Government. This form should be in counterfoil, duplicate and original. The counterfoil is to be retained by the purchasing dealer, the duplicate by the selling dealer and the original is to be furnished to the prescribed authority in accordance with the rules framed under section 13(4)(e) by the appropriate State Government. The form contains columns for giving, inter alia, the name of the purchasing dealer to whom issued along with his Registration Certificate No. The name of the seller has to be mentioned and it has to be certified that the goods ordered for in a specified purchase order were purchased from the selling dealer as per specified bill, cash memo and supplied under specified challan Nos. The purposes for which the goods were supplied are to be mentioned under four different heads. Thereafter, the purchasing dealer gives his address and puts also his signature. The State Government has also framed a set of rules for the purpose, under section 13(4)(a). We are now concerned with rules 10(1) and 10(2) framed by the Madras State Government. Rule 10(1) reads : "A registered dealer, who wishes to purchase goods from another such dealer on payment of tax at the rate applicable under the Act to sales of goods by one registered dealer to another, for the purpose specified in the purchasing dealer's certificate of registration, shall obtain from the assessing authority in the City of Madras and the registering authority at other places a blank declaration form prescribed under rule 12 of the Central Sales Tax (Registration and Turnover) Rules, 1957, for furnishing it to the selling dealer. Before furnishing the declaration to the selling dealer, the purchasing dealer or any responsible person authorised by him in this behalf, shall fill in all the required particulars in the form and shall also affix his usual signature in the space provided in the form for this purpose. Thereafter, the counterfoil of the form shall be retained by the purchasing dealer and the other two portions marked 'original' and 'duplicate' shall be made over by him to the selling dealer : ..... Thereafter, the counterfoil of the form shall be retained by the purchasing dealer and the other two portions marked 'original' and 'duplicate' shall be made over by him to the selling dealer : ..... No single declaration shall cover more than one transaction of sale ......." Rule 10(2) states : " A registered dealer who claims to have made a sale to another registered dealer shall, in respect of such claim, attach to his return in Form I the portion marked 'original' of the declaration received by him from the purchasing dealer. The assessing authority may, in its discretion, also direct the selling dealer to produce for inspection the portion of the declaration marked 'duplicate'" * It is urged by learned counsel for the petitioner that the intrinsic language of rule 10(1) would show that the rule would apply only to the purchasing dealers in the Madras State and not to those outside that State. Thus a registered dealer, who wishes to purchase goods from another is required to obtain from the assessing authority in the City of Madras and the registering authority at other places a blank declaration form. Obviously the Punjab purchasing dealers cannot be required to approach the assessing authority in the City of Madras for the purpose of obtaining a blank declaration form. "Assessing authority" is defined in the rules framed by the Madras State Government as any person authorised by the State Government to make any assessment under the Madras General Sales Tax Act, and "registering authority", as an officer of the State Government, specially empowered in this behalf. It is, therefore, clear that the assessing authority and registering authority mentioned in rule 10(1) refer only to the officers in the Madras State and the registered purchasing dealer must refer only to a dealer in the Madras State. The scheme of the Central Sales Tax Act dealing with inter-State sales is for the registered purchasing dealer to obtain appropriate C Forms from the authorities in his own State, and supply them after filling the particulars to the registered selling dealers in other States. Further, the foot-note at the bottom of C Form would show that, out of the three copies of C Form, the purchasing dealer has to retain one and send two to the selling dealer. Further, the foot-note at the bottom of C Form would show that, out of the three copies of C Form, the purchasing dealer has to retain one and send two to the selling dealer. For this purpose the purchasing dealer has to obtain C Forms from his own State and fill up the particulars. There is also the provision for punishment in rule 11 for contravention of rule 10. It is obvious that a Punjab purchasing dealer cannot be punished by the Madras Court for contravention of rule 10. These considerations leave no doubt in our minds that rule 10(1), in particular the provision therein requiring furnishing of separate C Form for each sale transaction, is intended to apply only to the purchasing dealers in the Madras State. It is obvious that the Madras State cannot legislate for the Punjab purchasing dealers or those in other States. They have to be governed by the appropriate rules framed by their own States. It is pointed out by learned counsel for the petitioner that corresponding rules framed by the Punjab State under section 13(4)(e) of the Central Sales Tax Act do not include a provision for the production of separate forms for each sale. We are, therefore, of the view that the Punjab purchasing dealers need only comply with the Punjab rules in the matter of supply of C Forms to the selling dealer, in Madras State, and rule 10(1) framed by the Madras State will not apply to them.The further question is whether, under the Central Sales Tax (Madras) Rules, a selling dealer is obliged to furnish as many C Forms as there are sales. Under rule 10(2) which we have extracted above, he is obliged to attach to his return in Form I, the portion marked "original" of the declaration in C Form received by him from the purchasing dealer. In this rule, there is no provision that he should file with his Form I return, as many C declarations as there are sales. If the purchasing dealers in Punjab have supplied the Madras selling dealer only the C Form as is required by the Punjab rules, it will not be proper to insist on the Madras selling dealer to comply with rule 10(1) enunciated for the purpose of registered purchasing dealers in Madras. If the purchasing dealers in Punjab have supplied the Madras selling dealer only the C Form as is required by the Punjab rules, it will not be proper to insist on the Madras selling dealer to comply with rule 10(1) enunciated for the purpose of registered purchasing dealers in Madras. According to the learned Government Pleader, if the Punjab rules do not provide for a separate C Form for each sale, the Madras selling dealer should correspond with the Punjab purchaser and persuade him to supply as many C Forms as there are sales, drawing his attention to the fact that, otherwise, the Madras selling dealer would be liable to pay 7 per cent. sales tax, and the purchasing dealer would consequently have to bear the burden of higher rate of assessment, the sales tax being included in the sale price. But this argument is open to objection that the Madras selling dealer cannot compel the Punjab purchasing dealers to comply with the rules in the above manner. Even if the Madras selling dealer points out to the Punjab purchasing dealer the advantage of obtaining a lower rate of assessment after complying with the Madras rule in the matter of supply of C Forms, the Punjab purchasing dealer, for reasons of his own, may not be able to supply as many C Forms as there are sales. Thus the Punjab Registering Authority (who has to supply C Forms to the Punjab purchaser) may tell him that he would be supplied with C Forms, only as required by the Punjab rules, and he could not get an excess in number of C Forms solely to accommodate the requirements of selling dealers in other States. It is mentioned by learned counsel for the petitioner that the Madras rule providing for as many C Forms as there are sales is prescribed in all the other States except three States of which Punjab is one. It is mentioned by learned counsel for the petitioner that the Madras rule providing for as many C Forms as there are sales is prescribed in all the other States except three States of which Punjab is one. We are unable to uphold the interpretation suggested by the Department of rule 10(1) as one which will apply to the registered purchasing dealers in the other States, who will be governed only by the rules framed in their own States.We asked the learned Government Pleader whether there are any special reasons for making it an essential requirement to supply as many C Forms as there are sales, in order to comply with section 8(4) of the Central Sales Tax Act. He is not able to point out any specific reason for requiring a separate C Form for each sale. What actually happens in a case where a purchasing dealer consolidates all his purchases in one form is that, instead of writing out all the particulars in different sheets of paper, he puts them in one paper, thereby ensuring economy of stationery. We called for and perused the C Forms issued by the Punjab purchasing dealers in this case. We found that they have noted in one form all the purchases made from the Madras selling dealer in the year of assessment. It could not be urged that any difficulty in verifications of sales would arise, if there is a consolidation of all the purchases by one purchaser from one dealer in one C Form. Further, we find that even rule 10(1) contains a provision that, where sales do not exceed Rs. 5, 000, one C Form would suffice. That would also be a pointer to show that there could be no intrinsic objection to having several transactions embodied in one C Form. It is submitted by the learned Government Pleader that all the sales in this case were not to the Punjab purchasing dealers, and there might have been a few items sold to purchasing dealers in other States. But the denial of lower rate of assessment is sought to be supported only on the basis of rule 10(1) as it prevails in the Madras State and not on the ground that there is a corresponding rule in the other States where purchases are made. But the denial of lower rate of assessment is sought to be supported only on the basis of rule 10(1) as it prevails in the Madras State and not on the ground that there is a corresponding rule in the other States where purchases are made. What we have stated above shows that rule 10(1) will apply to registered purchasing dealers in Madras State and the condition in that rule cannot be relied upon for denying the benefit of lower rate of assessment in a case where the selling dealer is found to have complied with the essential requirement both under the Act as well as the rules framed thereunder in the matter of supply of C Forms.For the above reasons we are of opinion that the order of the Tribunal is not right and that the assessee is entitled to the lower rate of assessment, because he has furnished declaration in C Form as required under the Act and the rules. The revision is allowed. There will be no order as to costs.