ORDER S.R. Alam, C.J. 1. In the instant writ petition the petitioner has assailed the validity of the order Annexure-P-4 dated 20.1.2005 passed under Section 14 of the Entry Tax Act and the order passed in revision authority dated 11.4.2007 by which the order passed by the Assessing Officer has been upheld. The petitioner has also challenged the propriety of action of respondents in levying penalty and interest. 2. Facts necessary for adjudicating the controversy involved in the writ petition briefly stated are that the petitioner is a company registered under the provisions of Companies Act. The petitioner-company is engaged in the business of sale and purchase of coal and is a registered dealer under the provisions of Commercial Tax Act, 1994. The petitioner purchased coal from M/s. Pawan Wires Limited, Panna and M/s. Vandana Fuels, Panna. Since the petitioner had made purchases from registered dealers, therefore, the same were presumed to be tax paid purchases. Accordingly, the petitioner submitted the return in respect of commercial tax as well as entry tax for a period from 1.4.98 to 31.3.99. 3. The Assistant Commissioner, Commercial Tax, Satna initiated proceeding for assessment of tax under Section 14 of the Entry Tax Act in respect of goods purchased by the petitioner from aforementioned two registered dealers. The respondent No.2 vide order dated 28.9.2000 rejected the petitioner's contention that in the absence of statement as provided under section 7(1) of the Act, the valid presumption arose in favour of the petitioner that the goods purchased by it are entry tax paid goods and, therefore, the petitioner is not liable to pay entry tax. Being aggrieved by the aforesaid order the petitioner preferred a revision before the Additional Commissioner, Commercial Tax. By order dated 11.2.2002 the matter was remanded to the Assessing Officer. 4. The Assessing Officer once again vide order dated 20.1.2005 held the petitioner liable for payment of entry tax. It was found by the Assessing Officer that the petitioner had made purchases from registered dealers i.e. M/s.Pawan Wires Ltd. and M/s.Vandana Fuels, which were new industries and were exempted from payment of commercial tax as well as entry tax. The goods purchased by the petitioner from aforementioned units were therefore not tax paid goods in the hands of the petitioner. Accordingly, the petitioner was held liable for payment of entry tax which was quantified at Rs.4,49,935/-. The goods purchased by the petitioner from aforementioned units were therefore not tax paid goods in the hands of the petitioner. Accordingly, the petitioner was held liable for payment of entry tax which was quantified at Rs.4,49,935/-. Being aggrieved by the aforesaid order the petitioner once again preferred the revision. However, the order of the assessing officer was upheld by the revisional authority vide order dated 11.4.2007 (Annexure-P-6). In the aforesaid factual backdrop the petitioner has visited this Court. 5. The respondents have filed return inter alia stating that an inspection was carried out on 8.1.99 and certain records were seized and thereupon, the proceedings under section 14 of the Entry Tax Act were initiated against the petitioner. The petitioner had made purchases from new industrial units which were enjoying facility of exemption from payment of entry tax and commercial tax. In the bills issued by the aforesaid units, seal has been affixed by the dealers stating that goods are exempted from entry tax and, therefore, the petitioner is liable to pay the entry tax. It has further been contended that since the petitioner has evaded payment of entry tax, therefore, it has to discharge it's statutory liability. The tax has rightly been levied, and the penalty and interest has rightly been imposed on the petitioner. 6. Mr.G.N.Purohit, learned senior counsel appearing for the petitioner, contended that in view of proviso appended to section 3(1) of the Entry tax Act the petitioner is not liable to make payment of entry tax as the goods were purchased from the registered dealers. While referring to Section 7(1) of the Entry Tax Act it was contended that if the registered dealer does not affix the seal on the sale voucher stating that "local goods for..........(name of local area) entry tax not paid" then the presumption arises in favour of the purchasing dealer that goods are entry tax paid goods. He has further invited our attention to Rule 7 of M.P. Entry Tax Rules, 1976 which prescribes the manner of issue of bill, cash memo or invoice under section 7 of the Act and provides for the statement to be made affixing a rubber stamp that goods are local goods and are entry tax not paid goods. He has further invited our attention to Rule 7 of M.P. Entry Tax Rules, 1976 which prescribes the manner of issue of bill, cash memo or invoice under section 7 of the Act and provides for the statement to be made affixing a rubber stamp that goods are local goods and are entry tax not paid goods. While referring to sub-section (1) of Section 17 of Commercial Tax Act, 1994, learned senior counsel has contended that there could be variety of exemptions i.e. qua the dealer, class of dealer, the goods as well as class of goods. He has also drawn our attention to section 43 of Commercial Tax Act, 1994 which requires issuance of bills by a registered dealer stating that the unit is availing exemption facility and tax has not been paid on such goods. Reference has also been made to Rule 66 of the Commercial Tax Rules which prescribes the format of rubber stamp to be affixed by the exempted registered dealer on the bill as per sub-sections (3) and (4) of Section 43 of the Commercial Tax Act. Learned senior counsel has argued that burden of proof on the purchasing registered dealer is discharged by production of bills in which proper rubber stamp, as required by law, is not affixed. He has placed reliance on Full Bench decision of this Court in Mohan Singh and Sons vs. Commissioner of Sales Tax MP 29 VKN 243, Ranomal Ramesh Kumar vs. State of MP 18 VKN 53 and in the case of Marble City Motors Jabalpur v. Assistant Commissioner of Commercial Tax and others (2006) 8 STJ 595. 7. On the other hand, Mr.Kumaresh Pathak, learned Dy. Advocate General appearing for the State has contended that exemption from payment of tax under section 3 of the Act applies only when the entry tax is payable or paid by the selling registered dealer. Admittedly, petitioner has made purchases from units which were exempted from payment of entry tax. Therefore, the petitioner cannot be absolved from it's liability to pay entry tax. Admittedly, petitioner has made purchases from units which were exempted from payment of entry tax. Therefore, the petitioner cannot be absolved from it's liability to pay entry tax. He has also referred to proviso sub-section (2) of section 7 of the Act to contend that it was not necessary to make a statement referred to in sub-section (1) where goods are purchased by a registered dealer who effects the entry of such goods into a local area other than the local area, in relation to which such goods are local goods. It has further been pointed out in sale vouchers which have been filed by the petitioner cumulatively as Anenxure-P-1, a seal has been affixed to the effect that goods are entry tax exempted goods and, therefore, non affixture of seal as required by the rules would not absolve the petitioner from payment of tax. 8. We have considered the submissions made on both sides. Before proceeding to deal with the merits of the case it would be useful to refer certain relevant provisions of the Entry Tax Act, 1976. Section 2(d) & (which define the expressions "local area" and "local goods" read as under: 2(d) "local area" means the area comprised within the limits of a local authority. 2(f) "local goods " in relation to a local goods means goods of local origin as distinct from goods which enter into that local area. Section 3 of the Entry Tax Act reads as under :- 3. Incidence of taxation-(1) There shall be levied entry tax- (a) on the entry in the course of business of a dealer of goods specified in Schedule-II, into each local area for consumption, use or sale therein; and (b) on the entry in the course of business of a dealer of goods specified in Schedule-III into each local area for consumption or use of such goods but not for sale therein; and such tax shall be paid by every dealer liable to pay tax under the Vanijyik Kar Adhiniyam who has effected entry of such goods: Provided that no tax under this sub-section shall be levied- (i) in respect of goods specified in Schedule-II other than the local goods, purchased from a registered dealer on which entry tax is payable or paid by the selling registered dealer; Section 7(1) is reproduced for the facility of ready reference. 7. 7. Registered dealers to issue bill etc., stating that goods sold are local goods- (1) Every registered dealer who, in the course of his business, manufactures, produces or grows any goods specified in Schedule-II in a local area in such manner that the goods become local goods in relation to that local area, shall, on the sale of such local goods to any other registered dealer, issue to him a bill, invoice or cash memo specifically stating in such manner as may be prescribed that the goods being sold are local goods in relation to such local area and that no entry tax has been paid on such goods. Rule 7 of M.P. Entry Tax Rules, 1976 reads as follows:- 7. Manner of issue of bill, cash memo or invoice under section 7- A registered dealer required to issue bill, cash memo or invoice under sub-section (1) or sub-section (2) Section 7 shall, for each sale of local goods effected by him to another registered dealer, issue a bill, cash memo or invoice after recording therein the statement referred to in sub-section (1) of Section 7. The statement may be recorded by affixing a rubber stamp and, as far as may be, read as follows:- "local goods for....(enter here name of local area), entry tax not paid." Every such dealer shall also maintain the counterfoil or duplicate or each of such bill, cash memo or invoice and preserve it till the completion of assessment. 9. Section 17(1) of the Commercial Tax Act, 1994 empowers the State Government to exempt any class of dealers. Section 17(1) reads as under :- 17. Saving- (1) The State Government may by notification and subject to such restriction and conditions as may be specified therein, exempt whether prospectively or retrospectively, (i) (a) any class of dealers; or (b) any goods or class of goods, in whole or in part, from payment of tax under this act for such period as may be specified in the notification. "Section 43(3) of Commercial Tax Act, 1994 requires issuance of bill by registered dealer stating unit is availing exemption and tax is not paid on such goods. Section 43(3) is reproduced below for the facility of ready reference :- 43. "Section 43(3) of Commercial Tax Act, 1994 requires issuance of bill by registered dealer stating unit is availing exemption and tax is not paid on such goods. Section 43(3) is reproduced below for the facility of ready reference :- 43. Certain dealers to issue bills or cash memoranda.- (3) Every registered dealer, who in the course of his business sells any goods specified in schedule-II, which have been manufactured by an industrial unit in respect of which such unit is availing the facility of exemption from payment of tax in whole under any notification issued under the act repealed by this act or under this act, in pursuance of any scheme of the state government, shall issue to the purchaser a bill, invoice or cash memo specifically stating in such manner as may be prescribed, that the goods being sold are goods manufactured by an industrial unit availing the facility of exemption from payment of tax in whole and no tax has been paid on such goods. Rule 66(2) of the Commercial Tax Rules which prescribes the particulars required in a bill and cash memorandum reads as under:- 66. Particular required in a bill or cash memorandum.- (2) A registered dealer required to issue a bill, cash memo or invoice under sub section (3) or sub section (4) of Section 43 shall for each sale of goods effected by him to another registered dealer, issue a bill, cash memo or invoice entering all the particulars as specified in sub-rule (1) and also record a statement as referred to in sub-section (3) of Section 43. The statement may be recorded by affixing rubber stamp which read as follows:- "Goods sold are manufactured by industrial unit holding eligibility certificate/eligible for exemption and are exempt from payment of tax- Commercial Tax not paid" Every such dealer shall also maintain the counterfoil or duplicate of each of such bill, cash memo or invoice and preserve it till the completion of assessment. 10. After having noticed the relevant provisions of law we may now advert to the facts of the case. Admittedly, the petitioner has made purchases from new industrial units having facility of exemption from payment of entry tax and commercial tax. 10. After having noticed the relevant provisions of law we may now advert to the facts of the case. Admittedly, the petitioner has made purchases from new industrial units having facility of exemption from payment of entry tax and commercial tax. From perusal of sale vouchers which have been annexed cumulatively as Annexure-P-1 by the petitioner, it is apparent that it bears the seal to the effect that goods are exempted from payment of entry tax and commercial tax. The petitioner-company is situate at Satna whereas the industries from whom the purchases have been made are situate in Panna. The petitioner has caused the entry of the goods into another local area, namely, Satna for sale. 11. The entry tax is a tax on the entry of goods into a local area for consumption, use or sale in course of business of dealer of Schedule-II goods. The entry tax is a single point tax. Once entry tax is paid or liability is incurred on entry of Schedule-II goods into local area, entry tax is not leviable thereafter, though the goods are moved from that local area into another local area and so on. An assessee is liable to pay the entry tax only when he causes entry of goods into local area for consumption, use and sale therein. From clause (i) of proviso to Section 3(1) of the Entry Tax Act it is apparent that no tax under this sub-section shall be levied in respect of goods specified in Schedule-II other than the local goods purchased from a registered dealer on which the entry tax is payable or paid by the selling registered dealer. Admittedly, in the instant case, entry tax is neither payable nor paid by the registered selling dealer as the units from which the purchase has been made by the petitioner have been granted exemption from payment of tax. 12. In the instant case when the petitioner made purchase of goods at Panna and caused entry of goods into another local area, namely, Satna, the taxable event had occurred and, therefore, the petitioner has incurred the liability to make payment of tax. 12. In the instant case when the petitioner made purchase of goods at Panna and caused entry of goods into another local area, namely, Satna, the taxable event had occurred and, therefore, the petitioner has incurred the liability to make payment of tax. Clause (i) of proviso to section 3(1) clearly indicates that where the goods sold by registered selling dealer to the assessee are local goods, entry tax would not be payable by selling registered dealer and, therefore, when the goods are moved from that local area by the assessee, entry tax is payable. If a dealer seeks exemption from payment of tax, it is for him to show that taxable event had not occurred or that the goods had already moved from one local area to another local area and thereby enabling an inference to be drawn that taxable event had occurred with liability in another registered dealer to pay tax. That burden can be discharged by purchasing registered dealer by producing the bill which he receives from the selling registered dealer which does not contain the rubber stamp as required by Section 7 of the Entry Tax Act and Rule 7 of M.P. Entry Tax Rules to the effect that goods are local goods and Entry Tax has not been paid. By not affixing the rubber stamp endorsement selling registered dealer makes an implied representation that taxable event has already occurred with liability created either in him or in a registered dealer who dealt with the goods. Absence of rubber stamp endorsement is not conclusive but merely raises a presumption in favour of purchasing registered dealer. However, in the instant case merely because rubber stamp as required by the provisions of Entry Tax Act, 1976 and Commercial Tax Act, 1994 and the Rules framed thereunder is not affixed, the petitioner cannot escape its liability from payment of tax, as purchase of local goods was made at Parma by the petitioner and petitioner caused entry of goods into another local area namely Satna, and the sale vouchers bears the seal that goods are exempted from entry tax and commercial tax. 13. The Full Bench decision of this Court in Mohan Singh & Sons (supra) and Division Bench decision of this Court in Ranumal Ramesh Kumar (supra) are of no assistance to the petitioner. 13. The Full Bench decision of this Court in Mohan Singh & Sons (supra) and Division Bench decision of this Court in Ranumal Ramesh Kumar (supra) are of no assistance to the petitioner. Learned senior counsel has commended us to the observations made by Full Bench in paragraphs 15 & 16 of the judgment which have been made in different factual context. Our view that since petitioner has caused entry of goods into another local area, namely, Satna, taxable event had occurred and, therefore, the petitioner has incurred the liability to make payment of tax, finds support from the observations made by Full Bench in para 13 of its judgment. In Ranumal Ramesh Kumar's case also purchases were not made from registered dealers who were granted exemption from payment of tax. Similarly, in Full Bench decision of this Court also the purchases were not made from the units to whom exemption was granted from payment of tax. In Marble City Motors, supra the sale vouchers did not contain the seal, whereas in the instant case seal affixed on sale vouchers shows that goods ones exempted from entry tax and commercial tax. For the aforesaid reasons, the decisions relied on by the learned senior counsel are distinguishable and do not apply in the obtaining factual matrix of the case. 14. In view of preceding analysis, we are of the considered opinion that Assessing Officer has rightly held the petitioner liable for payment of tax and has rightly imposed the penalty and interest. The aforesaid order has rightly been affirmed in the revision. The orders passed by the Assessing Officer and the revisional authority do not call for any interference. 15. Consequently, we do not find any merit in the writ petition. The same deserves to and is hereby dismissed.