Registration certificate controls raw material classification, so reopening based on a contrary view could not stand.

The registration certificate described the disputed item as "scraps of batteries for reclamation of lead," and that entry bound the department for concessional tax purposes unless the certificate was cancelled or modified. Once the material stood included as raw material in the certificate, no further enquiry on that issue was warranted, and a contrary earlier administrative view could not displace the later Division Bench position. A reopening notice founded on the contrary view was therefore unsustainable and was quashed, with the writ petition succeeding and the reassessment notice set aside.

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Issues: Whether batteries scrap mentioned in the registration certificate could be treated as raw material for the petitioner's manufacturing activity so as to entitle the petitioner to concessional tax under the Act, and whether the impugned notice reopening the assessment could be quashed.

Analysis: The registration certificate specifically described the item as "Scraps of batteries for reclamation of lead, etc." The Court applied the principle that, for purposes of concessional tax on purchase of raw material, the entry in the registration certificate is binding on the department unless it is cancelled or modified. Once the item stands included as raw material in the certificate, no further enquiry on that question is warranted. The earlier view of the Board of Revenue treating old batteries scrap as not constituting raw material was held to be no longer good law in view of the later Division Bench decision. In these circumstances, the reopening notice based on the contrary view could not be sustained.

Conclusion: The impugned notice was liable to be quashed, and the petitioner was entitled to the relief sought.

Final Conclusion: The writ petition succeeded, and the reassessment notice was set aside on the footing that the registered description of the raw material bound the department.

Ratio Decidendi: Where a material is shown in the dealer's registration certificate as raw material for manufacture, the department is bound by that entry unless the certificate is cancelled or modified, and cannot deny concessional treatment on a contrary subsequent view.

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