Registration certificate renewal relates back to the financial year, supporting exemption for earlier sales.

Renewal of a purchasing dealer's registration certificate was treated as operating for the entire financial year for which it was granted, because the Act and Rules did not limit renewal to the date of the renewal order. Although the application had to be filed in advance and inquiries could be completed later, the scheme and prescribed form indicated that renewal related back to the commencement of the year. The proviso to rule 27(2) was read consistently with that position, as it focused on whether the certificate had been renewed for the relevant year. Sales made before the renewal order were therefore entitled to exemption.

---

---

Issues: Whether renewal of a purchasing dealer's registration certificate for a financial year takes effect from the commencement of that year, so as to support exemption for sales made before the renewal order was actually passed.

Analysis: The relevant scheme treated a registration certificate as valid for the financial year and permitted renewal from year to year. The Act and the Rules did not state that renewal operated only from the date of the renewal order. The renewal application had to be made in advance, but the authority could complete inquiries later; the language used in the Rules and the form indicated that renewal related to the entire financial year for which it was granted. The proviso to rule 27(2) did not alter that position, because it turned on whether the certificate had been renewed for the year during which the purchase was made, not on the exact date of the renewal order.

Conclusion: Renewal of the registration certificate had limited retrospective effect from the beginning of the financial year, and the sales in question were entitled to exemption. The answer to the referred question was in the affirmative.

---