Tax liability accrues on crossing the turnover limit, and voluntary registration cannot defer assessment under sales tax law.

Tax liability under the Orissa Sales Tax Act arose when a dealer's turnover crossed the statutory limit, and it was not postponed by later registration or by an application for registration. Section 9 governed the consequences of non-registration by a dealer already liable, while section 9-A only permitted voluntary registration before liability accrued. The earlier voluntary-registration ruling did not apply where liability had already arisen under section 4. Assessment therefore had to proceed from the date liability was incurred, with the result favouring the Revenue.

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Issues: Whether a dealer who had already incurred liability under section 4 of the Orissa Sales Tax Act, 1947 could defer assessment until the date of registration under section 9-A or the date of application for registration, or whether liability attached from the date on which the turnover crossed the statutory limit.

Analysis: The liability to pay tax under section 4 arises on the dealer crossing the prescribed turnover limit and is not contingent upon registration under section 9 or voluntary registration under section 9-A. Section 9 deals with the consequences of non-registration by a dealer already liable, while section 9-A merely enables voluntary registration even where liability has not yet accrued. The question decided in the earlier voluntary-registration context did not govern a case where liability had already arisen under section 4.

Conclusion: The dealer's liability was not deferred to the date of registration or the date of application for registration. The assessment had to proceed from the date on which liability was incurred under section 4, and the answer was in favour of the Revenue.

Ratio Decidendi: Where a taxing statute makes liability depend on turnover crossing a statutory limit, that liability accrues independently of registration, and voluntary registration cannot postpone the date from which tax becomes payable.

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