Sales tax liability begins when taxable turnover is crossed, not when registration certificate is issued.

Sales tax liability arises when a dealer's gross turnover crosses the taxable limit; registration is only procedural and does not postpone the charging of tax until the certificate is issued. An application for registration made in time may protect the dealer from penal consequences for non-registration, but it does not create an exemption for the intervening period while the application remains pending. Where the assessee was registered on the relevant dates, assessment under the return-based procedure was proper. Delay in issuing the registration certificate may justify discretionary relief on facts, but it does not alter the statutory commencement of liability.

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Issues: Whether a dealer whose application for registration remained pending could be assessed to sales tax for the intervening period, and whether liability to pay tax arose only on the issue of the registration certificate.

Analysis: Liability under the charging provision accrued as soon as the dealer's gross turnover exceeded the taxable limit. The registration provisions regulated the procedure for carrying on business and making returns, but they did not postpone the accrual of liability until the certificate was actually issued. A dealer who applied in time avoided the penal consequences attached to failure to register, but no provision exempted him from tax for the period during which the application remained pending. Assessment under the return-based procedure was proper where, on the relevant dates, the assessee had already become a registered dealer. Any relief on account of delay in issuance of the certificate was a matter of discretion on the facts, not a rule of law postponing liability.

Conclusion: The dealer was liable to be assessed for the period notwithstanding the pending registration application, and the question was answered in the affirmative.

Final Conclusion: Tax liability arose when the taxable turnover threshold was crossed, and subsequent registration did not wipe out liability for the intervening period.

Ratio Decidendi: Under the sales tax statute, registration is procedural and does not determine the commencement of liability, which begins when the charging provision is attracted by the dealer's turnover.

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