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Issues: Whether a dealer registered under the C.P. and Berar Sales Tax Act, 1947, before the reorganisation of States continued to be a registered dealer in the new State of Madhya Pradesh for business carried on there when no place of business in that area was specified in the registration certificate.
Analysis: The statutory scheme showed that registration was granted with reference to the dealer's place or places of business, not to the entire territorial area of the State. The application for registration required disclosure of the main and additional places of business, the registration certificate had to specify the location of the business and any branch, and a dealer was required to inform the authority of changes or new places of business. Although turnover from all places of business in the State was relevant for determining liability to tax, the certificate itself remained location-specific. The provisions of the States Reorganisation Act did not alter the substance of the registration scheme so as to treat undisclosed places as covered by the earlier certificate.
Conclusion: The respondent could not be treated as a registered dealer in the new State of Madhya Pradesh in respect of business carried on at places not specified in the registration certificate; it was to be treated as an unregistered dealer vis-a-vis those places.
Final Conclusion: The appeal failed because the earlier registration certificate did not extend to the undisclosed places of business in the reorganised State, and the High Court's answer in favour of the respondent was affirmed.
Ratio Decidendi: A sales tax registration certificate is confined to the places of business disclosed in it, and after state reorganisation it does not automatically extend to undisclosed places within the new State.