Voluntary sales tax registration: liability starts on receipt of the certificate, not on application or grant of registration.

Voluntary registration under section 9-A of the Orissa Sales Tax Act commences sales tax liability only when the registration certificate is received by the dealer. The distinction from compulsory registration under section 9 was material: compulsory registration may track the point when statutory liability arises under section 4, but a voluntary applicant is not yet liable under that provision and seeks registration for statutory benefits. The court rejected relation back to the date of application, holding that such an approach would prejudice the dealer and that precedent under section 9 did not govern voluntary registration. Liability therefore begins on receipt of the certificate, not on application or grant of registration.

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Issues: Whether, on an application for voluntary registration as a dealer under section 9-A of the Orissa Sales Tax Act, liability to pay sales tax commences from the date of application, the date of grant of registration, or the date on which the registration certificate is received.

Analysis: The distinction between compulsory registration under section 9 and voluntary registration under section 9-A was material. In the case of compulsory registration, liability may relate to the point when the dealer becomes statutorily liable under section 4. Under voluntary registration, however, the dealer is not yet liable under section 4 and seeks registration only to obtain statutory advantages. The Court held that applying a relation-back principle to the date of application would prejudice the dealer rather than confer any benefit, and that the earlier precedent dealing with section 9 did not govern this situation.

Conclusion: Liability under section 9-A commences from the date on which the registration certificate is received by the dealer, and not from the date of application or the date of registration.

Ratio Decidendi: For voluntary registration under section 9-A, the commencement of sales tax liability is fixed by receipt of the registration certificate, not by relation back to the application date.

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