Retrospective cancellation of dealer registration cannot defeat valid declaration forms issued before cancellation for tax exemption claims.

Cancellation of a dealer's registration cannot operate retrospectively to invalidate declaration forms issued while the registration remained valid. Where a purchasing dealer claimed sales tax exemption on the strength of such forms for a prior assessment year, the later cancellation of the supplier's registration did not relate back to defeat the exemption. The settled principle applied is that documents issued during the currency of a valid registration retain effect, and subsequent cancellation cannot be used to deny the purchaser's statutory entitlement on that basis.

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Issues: Whether cancellation of the issuing dealer's registration certificate could operate retrospectively so as to invalidate declaration forms issued before the cancellation and deny sales tax exemption to the purchasing dealer.

Analysis: The assessment related to a prior assessment year in which the assessee claimed exemption on the strength of declaration forms issued by the supplier. The decisive consideration was that the supplier's registration had been cancelled only subsequently. On the settled principle applied by the Court, a declaration issued when the dealer held a valid registration remains effective, and later cancellation of the registration cannot relate back to defeat the purchasing dealer's entitlement.

Conclusion: Retrospective effect was not available to the cancellation order, and the declaration forms could not be invalidated on that basis.

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