Registered dealer liability survives a lease arrangement where business continues in the dealer's name and tax evasion is shown.

A registered dealer who allows a lessee to continue business in the dealer's name and to use the dealer's registration number and statutory forms may remain connected with the business for sales tax purposes. Where the facts show collusion or an arrangement designed to evade tax, the revenue can pursue recovery of the dues despite the lease structure. The non-retrospective character of section 19C did not, on these facts, prevent assessment and recovery under the statutory scheme governing registration, discontinuance of business, and collection of tax dues.

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Issues: Whether the appellant, as lessor and registered dealer, remained liable for sales tax dues arising from business conducted by the lessee in the appellant's trade name and using the appellant's registration number and statutory forms.

Analysis: The business continued in the old name with the appellant's permission, the lessee used the appellant's registration number and forms, and the factual findings showed collusion and an arrangement designed to evade tax. The statutory scheme of registration under the sales tax law was meant to ensure identification of the dealer and effective recovery of public dues. The Court treated the transaction as one where the appellant, for tax purposes, remained connected with the business and could not avoid liability by relying on the lease arrangement. Although section 19C was not retrospective, the assessment and recovery proceedings were still sustainable on the facts and under the statutory framework governing registration, discontinuance of business, and recovery of tax dues.

Conclusion: The appellant was liable for the assessed sales tax dues, and the challenge to the recovery failed.

Ratio Decidendi: Where a registered dealer permits another to carry on business in its name and on its registration, and the facts show collusion or evasion, the dealer cannot escape sales tax liability by relying on the lease arrangement; the revenue may proceed to recover the dues according to law.

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