Deeming explanation under sales tax law validly expands dealer definition and covers specified growers without separate tests.

Explanation II to section 2(e) of the Andhra Pradesh General Sales Tax Act was treated as a valid deeming provision because its language clearly brought specified growers selling processed agricultural produce within the definition of "dealer". The court held that the label "explanation" was not controlling where the operative words created a legal fiction. It further held that a grower covered by that fiction did not need to separately satisfy the original elements of the main definition of dealer, because the provision was self-contained and had to be given full effect. The challenged assessment was therefore sustained.

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Issues: (i) Whether Explanation II to section 2(e) of the Andhra Pradesh General Sales Tax Act was invalid on the ground that an explanation could not enlarge the scope of the main definition of "dealer"; (ii) Whether a grower falling within Explanation II was required, in addition to the deeming fiction, to satisfy the requirements of the main definition of "dealer".

Issue (i): Whether Explanation II to section 2(e) of the Andhra Pradesh General Sales Tax Act was invalid on the ground that an explanation could not enlarge the scope of the main definition of "dealer".

Analysis: The language of Explanation II was clear and unambiguous and created a legal fiction bringing within the definition of dealer a specified class of growers who sell processed agricultural produce. The caption of a provision as an explanation is not decisive of its true character. An explanation may clarify, add to, or introduce a legal fiction into the statutory text, depending on its own terms and legislative intent. The mere fact that the provision was labelled an explanation did not make it invalid, and the court declined to treat the title as controlling where the operative words were explicit.

Conclusion: Explanation II was valid and could operate to include the specified growers within the definition of dealer.

Issue (ii): Whether a grower falling within Explanation II was required, in addition to the deeming fiction, to satisfy the requirements of the main definition of "dealer".

Analysis: A deeming provision must be given full effect and carried to its logical conclusion. Explanation II was a self-contained provision for the class of growers described in it and, by legal fiction, made them dealers for the purposes of the Act. Once the legislature deemed such a grower to be a dealer, it was unnecessary to further test that person against the original elements of the main definition, which would defeat the purpose of the deeming clause.

Conclusion: A grower covered by Explanation II was not required to independently satisfy the main definition of dealer.

Final Conclusion: The challenged assessment could not be disturbed, as the growers who sold the processed produce fell within the deeming provision and were liable to be treated as dealers under the Act.

Ratio Decidendi: A clear and unambiguous deeming explanation may validly enlarge the class covered by the principal provision, and a person brought within such a legal fiction need not independently satisfy the original definition if the statute shows that the fiction was intended to be self-contained.

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