Registered dealer status is essential for liability under the Madras General Sales Tax Act offence.

Prosecution under Section 13 read with Section 15(h) of the Madras General Sales Tax Act required proof that the accused fell within the class bound by Section 13, namely a registered dealer or licensed person. The Court held that the statutory distinction between a dealer and a registered dealer could not be ignored, and that the use of "dealer" in return and assessment provisions did not dispense with proof of registration for criminal liability. As no evidence established that the accused was a registered dealer, the essential status for the offence was not proved and conviction could not be sustained.

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Issues: Whether the accused could be prosecuted under Section 13 read with Section 15(h) of the Madras General Sales Tax Act without proof that he was a registered dealer under the Act.

Analysis: Section 13 imposed the duty to keep and maintain true and correct accounts only on a registered dealer or a licensed person. The statutory scheme distinguished between a dealer and a registered dealer, and Section 8A required registration in the case of dealers above the prescribed turnover. Section 9(1) used the expression "dealer" for return and assessment purposes, but that did not dispense with the need to prove registration for an offence under Section 13. On the record, no evidence established that the accused was a registered dealer within the meaning of the Act.

Conclusion: The prosecution failed to prove the essential status required for liability under Section 13 read with Section 15(h), and the accused could not be convicted on the material before the Court.

Ratio Decidendi: An offence under Section 13 of the Madras General Sales Tax Act can be made out only against a person proved to be a registered dealer or otherwise within the class expressly bound by that provision.

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