JUDGMENT The judgment of the Court was delivered by S. L. SARAF, J. - This writ appeal arises out of a judgment and order dated August 12, 1994. The brief facts are as follows : The petitioner-appellant is a private limited company and carries on the business of cultivation, manufacture and sale of tea. The petitioner-appellant is registered as dealer under section 7 of the Central Sales Tax Act, 1956 (hereinafter referred to as "the Central Act"), in respect of all the tea estates owned by it. The petitioner-appellant is also registered as a dealer under the Assam Sales Tax Act, 1947 (hereinafter referred to as "the Assam Act"). That the petitioner-appellant in course of carrying business despatched tea from its different tea estates in Assam to Calcutta and Guwahati for sale. Tea was also despatched from the tea estates of the petitioner-appellant to other States for selling the same through different consignment agents appointed for the purpose. The petitioner-appellant has been regularly submitting its return of turnover showing therein the particulars of sale in the prescribed form as required under the Central Act and the Assam Act and the taxes were also paid from time to time as required by law. Assessments were also made from time to time by the Superintendent of Taxes, Tinsukia. That for the period ending March 31, 1980 the petitioner-appellant submitted its return of turnover with the Superintendent of Taxes. Tinsukia, respondent No. 3 (i.e., Civil Rule No. 65 of 1989). The petitioner-appellant appeared before the Superintendent of Taxes, Tinsukia in compliance with the notice issued under section 17(2) of the Assam Act read with section 9(2) of the Central Act and produced the books of account and documents in support of the return. The petitioner-appellant also filed all relevant "F" forms in support of the transfer of tea to the various agents of the petitioner-appellant in the States of Maharashtra and Gujarat for sale on consignment basis. It was contended that these transfers were by way of stock-transfer otherwise than by way of sale and as such, the petitioner-appellant was not liable to pay tax under the Central Act and as such no tax was paid by the petitinoer-appellant. These facts were accepted by the Superintendent of Taxes and assessment was completed vide order dated January 23, 1981 under section 17(3) of the Assam Act read with section 9(2) of the Central Act. These facts were accepted by the Superintendent of Taxes and assessment was completed vide order dated January 23, 1981 under section 17(3) of the Assam Act read with section 9(2) of the Central Act. A copy of this order is at annexure I to the writ application. That on April 15, 1981 the Inspector of Taxes, seized some books of account and documents of the petitioner-appellant-company in the purported exercise of power under section 44(3) of the Assam Act. The petitioner-appellant-company was thereafter served with notice dated May 20, 1981 purported to be a notice under section 19A of the Assam Act read with section 9(2) of the Central Act. By the aforesaid notice the manager of the tea estate was informed that the turnover of the period ending September 30, 1978, March 31, 1979 and March 31, 1980 had escaped assessment. A copy of the aforesaid notice is dated May 20, 1981 at annexure II to the writ application. That the Superintendent to Taxes, Tinsukia, vide order dated July 22, 1981 reassessed the turnover of the petitioner-appellant treating the despatches made by the petitioner-appellant outside the State of Assam to the agents by way of sale as inter-State sales and they demanded a sum of Rs. 20,282 on account of tax and Rs. 13,080 on account of interest was raised on the petitioner-appellant for the period being September 30, 1978. The petitioner-appellant preferred appeal before the Assistant Commissioner of Taxes (Appeals) Jorhat. The Assistant Commissioner of Taxes (Appeals) vide his order dated April 5, 1983 on consideration of the application to pay 25 per cent of the disputed demands for each of the period. Ultimately these appeals were transferred to the Assistant Commissioner of Taxes (Appeals), Tinsukia. The Assistant Commissioner of Taxes (Appeals), Tinsukia, heard the appeals and the main contention was that the burden on the assessee is discharged on the filing of the "F" forms as prescribed by rule 12(5) of the Central Sales Tax (Registration and Turnover) Rules, 1957 and that the conditions precedent for exercise of powers under section 19A was wholly non-existent. A written argument was also filed before the appellate authority and that is annexure VI to the writ application. A review application was filed before the Commissioner of Taxes, Assam, Guwahati. A written argument was also filed before the appellate authority and that is annexure VI to the writ application. A review application was filed before the Commissioner of Taxes, Assam, Guwahati. The Commissioner of Taxes rejected the review application by a common order dated June 24, 1988 holding that the Superintendent of Taxes has rightly assessed the turnover, i.e., annexure IX to the writ application. Thereafter the demand notice was served on the petitioner-appellant to pay the impugned demand within November 11, 1988. 2. That the writ petitioner (appellant) moved an application under article 226 of the Constitution of India which was numbered as Civil Rule No. 65 of 1989 for the following prayer : "(i) to quash the impugned order dated June 24, 1988 (annexure IX), (ii) to quash the order dated December 30, 1986, passed by the respondent No. 2, the Assistant Commissioner of Taxes (Appeals) (annexure VIII), (iii) to quash the impugned order of reassessment dated July 22, 1981 passed by the Superintendent of Taxes, Tinsukia (annexure III) and to quash the impugned notice dated November 3, 1988 issued by the respondent No. 3, the Superintendent of Taxes, directing the petitioner-appellant to pay the impugned demand on account of tax and interest (annexure I). In Civil Rule No. 66 of 1989 the prayers are same. In Civil Rule No. 67 of 1989 also the prayers are same." 3. No affidavit-in-opposition was filed in the writ application by the respondents. However, the respondents produced photo copies of the records. The learned Judge on consideration of the submissions made by the petitioner-appellant at the time of hearing of the application as well as the counsel for the respondents and on the basis of the documents filed along with the writ petition and the documents produced by the respondents authorities at the time of hearing of the application considered the matter at length and was pleased to hold that the transfer of the goods from the State of Assam to the States of Maharashtra or Gujarat was inter-State sale and not a stock transfer as claimed by the writ petitioner (appellant) and upheld the orders passed by the tax authorities. As against the said judgment the counsel for the appellant had urged two points, firstly, the use of the expression buyer or seller is not conclusive if the transaction was in the nature of stock transfer, the use of the word buyer would not make the said transaction a sale. For this purpose the counsel relies on the decision of the Supreme Court as reported in [1988] 70 STC 107 (Alwaye Agencies v. Deputy Commissioner of Agricultural Income-tax and Sales Tax, Ernakulam). The second point urged was that the assessee submits "F" form relating to the movement from one State to another with full particulars provided therein. The tax authority has to accept the same and cannot ask for any further or other evidence and should treat the movement of the goods as stock transfer from one State to another. The authorities cannot thereafter to behind the said "F" form and make a finding contrary to the particulars contained in the declaration furnished by the dealer under sub-section (1) of section 6A. We have carefully considered the submissions made by Dr. A. K. Saraf on behalf of the writ petitioner (appellant) and do not find any substance in the same. The single Judge has carefully gone into the factual position of the transaction including the agreement between the parties and the various other documents furnished to the court at the time of hearing of this writ application whereby the movement of goods from one State to another has taken place. The learned Judge has also noticed that in the writ application it is nowhere alleged that the firm issuing "F" form were agents of the petitioner (appellant). Under section 6A(1) of the Central Sales Tax Act, 1956 the burden is on the dealer to prove that the movement of goods was occasioned not by reason of sale, but was occassioned by reason of transfer of such goods by him to any other place of his business or his agent or principal outside the State. The burden so cast on the dealer cannot be discharged by merely furnishing the declaration as prescribed (F forms) along with the evidence of despatch of such goods. Furnishing of the declaration (F forms) is not conclusive or mandatory. The burden so cast on the dealer cannot be discharged by merely furnishing the declaration as prescribed (F forms) along with the evidence of despatch of such goods. Furnishing of the declaration (F forms) is not conclusive or mandatory. In cases where the dealer exercises the option of furnishing the declaration (F forms), further requirement is that the assessing authority should be satisfied, after making such enquiry, as he may deem necessary, that the particulars contained in the declaration furnished by the dealer are "true". It is not possible or practicable to lay down the exact documents or materials that may be required in all the cases, by the assessing authority, to come to a proper and just finding as required by section 6A(2) of the Act. 4. The authorities reopened the case by exercising power under section 44(3) of the Assam Act and thereafter heard the matter afresh and considered all the documents including the purported agency agreement and on finding of fact arrived at the conclusion that the particulars furnished in the declaration form were not true and the transaction was not that of stock transfer but was inter-State sale. So the tax authorities considered the acceptance of "F" form as irrelevant and collection of "C" form imperative. Accordingly, the authorities assessed the sale transaction of the escaped turnover. The case reported in [1990] 76 STC 211 (C. P. K. Trading Company v. Additional Sales Tax Officer) was relied on by Dr. A. K. Saraf in support of his contention that once the "F" form is furnished with all particulars, the same is conclusive and the tax authority is bound to assess the transaction as stock transfer. In our view of the matter, the said decision does not support the aforesaid contention of the appellant. According to the said decision it is the burden of the assessee to prove that the movement of the goods was occasioned not by reason of sale but occasioned by reason of transfer of such goods. Furnishing of "F" form is neither conclusive nor mandatory. It is for the dealer to discharge the burden of proof of the transaction by adducing proper evidences. If the transaction is not genuine transaction of transfer of goods from one place to another by reason of stock transfer, the same could be rejected by the assessing authority under section 6A(2) of the Act. It is for the dealer to discharge the burden of proof of the transaction by adducing proper evidences. If the transaction is not genuine transaction of transfer of goods from one place to another by reason of stock transfer, the same could be rejected by the assessing authority under section 6A(2) of the Act. The learned single Judge has considered in details the findings made by the sales tax authorities and had found no inherent infirmity in the same. We have also considered the findings of the tax authorities and order passed by the learned single Judge and confirm the same. 5. In the result, the appeal stands dismissed. There will be no order as to costs. Appeal dismissed.