JUDGMENT P.C. BALAKRISHNA MENON, J. The only question urged by counsel on both sides before us is relating to the interpretation of sub-rule (14) of rule 32 of the Kerala General Sales Tax Rules. As per the said rule a dealer in goods taxable at the point of last purchase in the State may prove that he is not the last purchaser by the production of a declaration in form 25 obtained from the person to whom he has sold the goods. The declaration is to be submitted to the assessing authority within the time specified in sub-rule (14) of rule 32 and it should contain the particulars mentioned therein. The assessees in these cases had submitted such declarations in form 25 with respect to part of the turnover involved in these cases. If the declaration is accepted, such part of the turnover as is covered by the declaration is not taxable in the hands of the assessee. The incidence of the tax at the last purchase point will be on the purchaser who has issued the declaration under form 25. 2. In T.R.C. No. 92 of 1983, the Appellate Tribunal found that the assessee is not taxable as the last purchaser with respect to the turnover covered by the declaration in form 25. In the other two cases the Tribunal took a different view and held that the declarations cannot be accepted as there are indications in the bills issued as well as in the declarations that the purchaser had deducted the commission due to him from the price of the goods purchased by him. 3. There is no dispute that the purchaser in all these cases are registered dealers. The particulars of registration are shown in the respective declarations issued by them. The requirement of such declaration as per sub-rule (14) of rule 32 is to ensure that the tax due to the Government at the last purchase point is collected from the purchaser at that point and the method of proof of the last purchase point provided for in the sub-rule itself is by the production of the declaration in form 25. Once such a declaration is produced, the incidence of taxation at the last purchase point is on the purchaser who issues the declaration. Once such a declaration is produced, the incidence of taxation at the last purchase point is on the purchaser who issues the declaration. These provisions are intended to ensure that there is no tax evasion in cases where the incidence of taxation is at the last purchase point. Construing a similar provision in rule 28(1) of the Rules a Division Bench of this Court in Deputy Commissioner of Sales Tax v. Bharat Refineries Ltd. [1978] 42 STC 225 stated at page 231 : "7. ........ When once the declaration in the prescribed statutory form is obtained from the purchasing dealer and furnished to the authorities, the selling dealer satisfies the requirements of the statute and he is entitled to claim the concessional rate of one per cent, irrespective of the correctness of the declaration or the manner in which the declarant subsequently acts ......." A learned Judge of this Court in the decision in Rehmath Trading Co. v. Sales Tax Officer [1980] 46 STC 25 construing sub-rule (14) of rule 32 stated at page 30 : "9. But sub-rule (14) postulates a different situation. Here the goods have not suffered tax at any point of time and the dealer claims exemption on the ground that the sale in question is in favour of another dealer who is liable to tax. The only effective means of verification of the identity of the purchaser as such dealer to enable the seller to claim the exemption as per entry 72 is the production of the certificate of registration as required under sub-rule (14). If sub-rule (14) is read as directory it would in many cases be practically impossible for the concerned authorities to verify the genuineness of the claim for exemption. Section 13 compels the registration of all dealers who are liable to pay tax under section 5. Consequently, the exemption under entry 72 can extend only to those dealers who are in a position to establish that the sales in question were effected in favour of the dealers possessed of certificates of registration which is the best evidence to attract the exemption. Registration is the statutory proof of the status of the purchaser and form 25 is the surest means of establishing the seller's claim to exemption. This is what is sought to be accomplished by the mandatory provisions contained in rule 32(14). Registration is the statutory proof of the status of the purchaser and form 25 is the surest means of establishing the seller's claim to exemption. This is what is sought to be accomplished by the mandatory provisions contained in rule 32(14). In the circumstances, the contention that sub-rule (14) has to be read as directory has no substance." In view of these pronouncements of this Court we are clearly of the view that turnover covered by the form 25 declarations issued by registered dealers cannot be included in the taxable turnover of the assessees in these cases. We dismiss T.R.C. No. 92 of 1983. The impugned orders of the Tribunal in T.R.C. Nos. 5 and 6 of 1986 are set aside and the assessing authority is directed to make fresh assessment accepting the form 25 declarations produced before him. T.R.C. Nos. 5 and 6 of 1986 are accordingly allowed. No costs. T.R.C. No. 92 of 1983 dismissed. T.R.C. No. 5 and 6 of 1986 allowed.