Temporary sales tax registration requires bona fide entitlement; factual findings on a claimed new unit were upheld in writ jurisdiction.

Temporary sales tax registration is not granted mechanically on application alone; the authority may require an inquiry into the genuineness and bona fides of the dealer's claim before issuing a certificate. On the facts recorded, the applicant failed to cooperate by producing the required account books, and the authorities found that no new unit had come into existence and that the alleged unit was only a camouflage for an already covered activity. Those factual findings, based on inquiry and the record, were held not open to reappreciation in writ jurisdiction. The refusal to grant temporary registration was therefore upheld.

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Issues: Whether the sales tax authorities were bound to grant temporary registration on mere application, and whether refusal of registration for the alleged new unit was sustainable.

Analysis: Grant of registration under the relevant sales tax provisions depended on an inquiry into the genuineness and bona fides of the application. The authority was required to satisfy itself that the dealer was genuinely entitled to the certificate, and the extent of inquiry could vary according to the facts of each case. On the facts found in inquiry, the petitioner did not cooperate by producing the required account books, and the authorities concluded that no new unit had come into existence. The claimed new unit was found to be only a camouflage, while the earlier registration already covered the activity in question. Such factual findings, based on inquiry and record, were not open to reappreciation in writ jurisdiction.

Conclusion: The refusal to grant temporary registration was upheld, and the writ petition failed.

Ratio Decidendi: Registration under the sales tax law is not to be granted mechanically on application alone; the authority may insist on a bona fide, genuine entitlement established through inquiry, and factual findings on the existence of a new unit are binding in writ jurisdiction unless shown to be perverse.

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