Representative assessment under sales tax law must remain confined to each non-resident principal, not combined across principals.

Section 18 of the General Sales Tax Act, 1125 creates a representative liability by treating the resident agent as dealer for a non-resident principal, but that statutory fiction is limited to assessment of each principal separately. Because the scheme of liability, retention, and refund is tied to the business of each non-resident principal, a single consolidated assessment covering the turnover of all principals would extend the fiction beyond its permissible scope and conflict with the section's text and structure. Consolidated assessments were therefore impermissible and were quashed.

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Issues: Whether the assessments made by clubbing together the turnover of all non-resident principals represented by the assessee could be sustained under section 18 of the General Sales Tax Act, 1125.

Analysis: Section 18 creates a statutory fiction by treating the resident agent as the dealer for the business of a non-resident principal, but the fiction is confined to the assessment of each non-resident principal separately. The provision contemplates assessment with reference to the business of each principal, and the statutory scheme of liability, retention, and refund shows that the agent acts only as a representative for that principal. A single omnibus assessment covering the turnover of all non-resident principals would enlarge the fiction beyond its legitimate field and would not conform to the language or structure of the section.

Conclusion: The consolidated assessments were impermissible and were quashed. The assessee succeeded.

Ratio Decidendi: A statutory fiction creating representative liability must be confined to the precise purpose for which it is enacted, and under section 18 each non-resident principal requires a separate assessment.

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