Contextual interpretation of "registered dealer" under sales tax law upheld to preserve single-point levy and avoid multiple taxation.

The expression "registered dealer" in section 8(ii) of the Bombay Sales Tax Act, 1959 was construed contextually to include a dealer registered under the Central Sales Tax Act, 1956 who is liable to pay tax under section 4 of the Bombay Act, even if not separately registered under that Act. The Court held that a defined term may depart from its ordinary statutory definition where the scheme, subject and object of the statute so require. That wider reading was necessary to preserve the single-point levy structure and avoid multiple taxation on the same goods. The assessee was therefore entitled to the deduction claimed.

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Issues: Whether the expression "registered dealer" in clause (ii) of section 8 of the Bombay Sales Tax Act, 1959 includes a dealer registered under the Central Sales Tax Act, 1956 who is liable to pay tax under section 4 of the Bombay Sales Tax Act, 1959 though not registered under that Act.

Analysis: The definition of "registered dealer" in section 2(25) of the Bombay Sales Tax Act, 1959 is ordinarily exhaustive, but a defined expression may bear a different meaning where the subject, context, collocation and object of the statute so require. Clause (ii) of section 8 was enacted as part of a scheme to impose sales tax at a single point and to prevent multiple levy on the same goods. Section 4 of the Bombay Sales Tax Act, 1959 creates a special liability on a dealer registered under the Central Sales Tax Act, 1956 in respect of specified sales and places such dealer within the tax net for those sales. Reading section 4 with section 8, and applying the contextual rule of construction, the expression "registered dealer" in section 8(ii) cannot be confined only to a dealer registered under section 22 of the Bombay Act if that narrow meaning would defeat the legislative scheme. The contrary view would undermine the object of single point taxation and the legislative policy against repeated levy on the same goods.

Conclusion: The expression "registered dealer" in clause (ii) of section 8 of the Bombay Sales Tax Act, 1959 includes a dealer registered under the Central Sales Tax Act, 1956 who is liable to pay tax under section 4 of the Bombay Sales Tax Act, 1959. The assessee is entitled to the deduction claimed.

Ratio Decidendi: A defined term may depart from its statutory definition where the context, scheme and object of the Act require a wider meaning to avoid defeating the legislative intention of single point levy and prevention of multiple taxation.

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