Deeming provisions are confined to their statute and purpose; deemed registration under the Sales Tax Act did not extend to the Entry Tax Act.

A deeming provision must be confined to the statute and purpose for which it is created: a dealer treated as registered under section 7(4) of the M.P. General Sales Tax Act, 1958 could not automatically be treated as a registered dealer under the M.P. Entry Tax Act. Section 13 of the Entry Tax Act adopted only specified provisions of the Sales Tax Act, and section 7 was deliberately omitted. The legal fiction in section 7(4) operated only within the Sales Tax Act's machinery for purchase tax liability and could not be extended by implication to a different enactment. The deemed registration therefore did not carry over to the Entry Tax Act.

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Issues: Whether a dealer deemed to be a registered dealer under section 7(4) of the M.P. General Sales Tax Act, 1958 could be treated as a registered dealer under the M.P. Entry Tax Act although section 7 of the Sales Tax Act was not expressly adopted by section 13 of the Entry Tax Act.

Analysis: Section 13 of the Entry Tax Act applied only the specified provisions of the Sales Tax Act mutatis mutandis, and section 7 was deliberately omitted from that list. The deeming provision in section 7(4) was created for the limited purpose of making the machinery provisions of that Act applicable to purchasers liable under section 7, and such a legal fiction cannot be extended beyond its statutory context. The two enactments rested on different constitutional entries, and the omission of section 7 from section 13 showed that the Legislature did not intend the purchase-tax machinery or the deeming of registered dealer status to operate under the Entry Tax Act.

Conclusion: The dealer could not be deemed to be a registered dealer under the Entry Tax Act on the basis of section 7(4) of the Sales Tax Act.

Final Conclusion: The legal fiction of deemed registration was confined to the Sales Tax Act and could not be carried into the Entry Tax Act in the absence of express adoption.

Ratio Decidendi: A deeming provision must be confined to the purpose and context for which it is created and cannot be extended by implication to a different statute where the Legislature has not expressly adopted it.

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