Retrospective correction of sales tax registration certificates may apply where an omission was merely inadvertent.

An omission in a sales tax registration certificate can be treated as an inadvertent mistake where the application, the certificate and the parties' prior conduct show that the intended goods were meant to be covered. The court read the registration application together with the certificate and relied on the revenue authorities' earlier issuance of declaration forms and tax concessions to confirm that the omission did not reflect a merits-based refusal. In that situation, the proper course is to amend the certificate retrospectively from the original date of registration so it reflects the true position, and to issue declaration forms in accordance with the corrected registration.

---

---

Issues: Whether an error or omission in a sales tax registration certificate could be rectified retrospectively so as to include the goods intended to be covered by the dealer's application and to enable issue of declaration forms in accordance with that corrected certificate.

Analysis: The registration application and the certificate were read together, and the long course of dealing between the dealer and the revenue authorities showed that both sides had proceeded on the footing that the goods manufactured and the raw materials purchased for that manufacture were meant to be covered by the registration. The omission of the manufactured goods from the certificate was treated as an inadvertent mistake rather than a rejection on merits. The earlier conduct of the authorities in issuing declaration forms and granting tax concessions supported that view. In such a situation, the proper course was not to deny the dealer the benefit of the registration, but to correct the certificate so that it reflected the true position from the date of the original grant.

Conclusion: The omission in the registration certificate was held to be a correctable mistake, and the certificate was directed to be amended retrospectively from the original date of registration, after which declaration forms were to be issued to the dealer in accordance with law.

---