Aggregate turnover disclosure required for sales tax registration, and self-caused refusal cannot create estoppel against revenue.

Where sales tax liability attached to the entire business, an applicant for registration was required to disclose the aggregate turnover of all branches, not merely the turnover of one place of business. The assessee's failure to disclose the total turnover meant the refusal of registration was attributable to its own non-disclosure, so estoppel could not be invoked to prevent the revenue from assessing sales tax for the earlier period. The commentary also notes that the separate questions concerning assessment under section 11A and section 11(5) were left unanswered.

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Issues: Whether, in an application for sales tax registration of one place of business, the assessee was required to disclose the gross turnover of the entire business including other branches, and whether the department was estopped from recovering sales tax for the earlier period because registration for the Dholka shop had initially been refused.

Analysis: The liability to pay sales tax attached to the entire business, and effective registration depended on disclosure of the material facts bearing on that liability. The application form, as applicable in August 1946, was treated as requiring disclosure of the aggregate turnover of the assessee's business, even where business was carried on at more than one place. The assessee had not disclosed the total turnover and the refusal of registration was therefore attributable to his own failure of disclosure. In those circumstances, the department could not be prevented by estoppel from assessing sales tax for the relevant earlier period. The Court also noted, in the separate reference, that the questions concerning assessment under section 11A and section 11(5) were not answered.

Conclusion: The assessee was bound to disclose the turnover of the entire business in the registration application, and the plea of estoppel against the department failed. The sales tax recovery for the earlier period was upheld on this issue.

Final Conclusion: The references were answered substantially against the assessee on the principal question of estoppel and disclosure, while the remaining assessment questions were left unanswered.

Ratio Decidendi: Where liability to tax is referable to the whole business, an assessee seeking registration must disclose the aggregate turnover of all branches, and a refusal of registration caused by the assessee's own non-disclosure cannot found an estoppel against the revenue.

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