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Issues: Whether the assessee was entitled to the lower rate of tax under section 8(1) of the Central Sales Tax Act when the purchasing dealer obtained registration only after the date of sale but furnished declaration form C later.
Analysis: The lower rate under section 8(1) is available only where the sale is to a registered dealer on the date of sale. Registration after the transaction does not retrospectively convert an earlier sale to one made to a registered dealer. The furnishing of form C after registration cannot by itself establish that the purchaser was registered on the relevant date, nor can it cure the legal infirmity in a sale made before registration.
Conclusion: The assessee was not entitled to the benefit of the lower rate of tax, as the transaction was not a sale to a registered dealer on the date of sale.
Ratio Decidendi: For the concessional rate under section 8(1), the purchasing dealer must be registered on the date of sale, and subsequent furnishing of form C does not retrospectively satisfy that statutory requirement.