Tax registration follows liability to pay tax; the certificate cannot predate the first accrual of that liability.

Registration under the Central Sales Tax Act and the Delhi Sales Tax Act is linked to the dealer's liability to tax, so the certificate cannot be given an effective date earlier than the first accrual of that liability. The statutory scheme requires a liable dealer to apply for registration within the prescribed time, and the relevant rules make that period run from the date liability arises. On that reading, registration may relate back to the date of application only where the application is made after, or at the same time as, tax liability first arises. The same principle applies under the Delhi Sales Tax Act, where registration similarly follows liability to pay tax.

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Issues: Whether the registration certificate under the Central Sales Tax Act, 1956 and the Delhi Sales Tax Act, 1975 took effect from the date of application or from the date when liability to pay tax first arose.

Analysis: The scheme of the Central Sales Tax Act, 1956 makes registration and liability to pay tax coterminous. Section 7 requires a dealer liable to tax to apply for registration within the prescribed period, while Rule 4 of the Central Sales Tax (Registration and Turnover) Rules, 1957 fixes that period at 30 days from the date the dealer becomes liable. Section 6 fastens tax liability on inter-State sales, and section 3 identifies when such a sale or purchase occurs. Reading these provisions harmoniously, the registration certificate relates back to the date of the application only when the application is made after, or simultaneously with, the incurrence of tax liability. The same approach applies under the Delhi Sales Tax Act, 1975, where section 14 and the relevant rule similarly tie registration to liability to pay tax. A dealer cannot obtain an earlier effective date than the date on which tax liability first arises.

Conclusion: The registration certificate could not take effect from the date of application in the absence of prior liability to tax; it took effect from the date on which the dealer first became liable to pay tax, namely 21 June 1976.

Ratio Decidendi: Registration under these fiscal statutes becomes effective from the date of application only when the dealer has already incurred, or simultaneously incurs, liability to pay tax; the certificate cannot relate back to a date earlier than the first accrual of such liability.

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