Sales tax liability under voluntary registration begins only on receipt of the registration certificate, not on application filing.

In voluntary registration under the sales tax law, liability to pay sales tax begins only when the registration certificate is actually received, not when the application for registration is filed. The court followed its earlier ruling and held that assessment for the period before receipt of the certificate could not fasten tax liability on the dealer. The answer was therefore given in favour of the dealer and against the department.

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Issues: Whether the dealer's liability to pay sales tax commenced from the date of application for registration or only from the date of receipt of the registration certificate.

Analysis: The questions referred arose from the dealer's voluntary application for registration and the assessment made for the period before the registration certificate was received. The Court followed its earlier decision holding that, in such a situation, tax liability does not begin on the date of the application but only when the registration certificate is actually received by the dealer.

Conclusion: The liability to pay sales tax commenced only from the date of receipt of the registration certificate, not from the date of application for registration, and the answer was given in favour of the dealer and against the department.

Ratio Decidendi: In the case of voluntary registration under the sales tax law, tax liability arises only upon receipt of the registration certificate and not merely upon filing the application for registration.

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