Sales tax liability arises from the charging provision itself, not from registration application or certificate grant.

Liability to pay tax under section 4 of the Orissa Sales Tax Act arises when the statutory conditions in the charging provision are satisfied, and not from the date of application for registration or the date the registration certificate is granted. The obligation to register under section 9 follows the accrual of liability, while section 9-A permits voluntary registration before liability arises. Registration therefore has procedural significance only: it may confer administrative benefits, but it does not create, postpone, or control substantive tax liability. The point of accrual remains governed by section 4 alone.

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Issues: Whether liability to pay tax under section 4 of the Orissa Sales Tax Act accrues from the date of application for registration or only from the date on which the registration certificate is granted.

Analysis: Liability to tax under section 4 is independent of registration. The obligation to register under section 9 arises after liability under section 4 is attracted, while section 9-A merely permits voluntary registration even before liability accrues. Registration confers procedural benefits, but it does not create, postpone, or control the substantive liability to pay tax. The date of grant of registration certificate therefore cannot shift the point of accrual of liability once the statutory conditions in section 4 are satisfied.

Conclusion: Liability to pay tax accrues when the conditions of section 4 are satisfied and not from the date of application for registration or the date of grant of the registration certificate.

Ratio Decidendi: Under the sales tax scheme, substantive liability to tax arises from the charging provision itself and is not conditioned by registration.

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