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Issues: Whether a dealer carrying on photo-processing as a works contract is entitled to amendment of the Central Sales Tax registration certificate to include machinery and accessories for purchase against C forms.
Analysis: A dealer registered under the Central Sales Tax Act is entitled to seek amendment of the registration certificate under section 7(4) when the class of goods used in the business requires to be incorporated. The Court accepted that works contract activity, after the constitutional and statutory amendments recognising transfer of property in goods involved in execution of works contracts as a sale, does not deprive the dealer of the statutory benefits attached to registration. Once the dealer is engaged in an activity treated as works contract and is otherwise a registered dealer, inclusion of the relevant machinery and accessories for the business was held to be within the scope of the registration scheme and consistent with the right to obtain concessional purchasing facility.
Conclusion: The dealer was entitled to amendment of the Central Sales Tax registration certificate and to the consequential benefit of purchasing the goods through C forms.
Ratio Decidendi: A registered dealer executing a works contract is not excluded from seeking amendment of the Central Sales Tax registration certificate for goods required in the business, and the statutory registration benefits attach notwithstanding the character of the activity as works contract.
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