Consolidated registration requires reasoned discretion; arbitrary refusal without relevant consideration is vulnerable to challenge.

Rule 3(4) of the Bihar Sales Tax Rules, 1983 permits consolidated registration as an exception to separate registration for each place of business, intended to reduce harassment while preserving administrative convenience. The Commissioner's discretion must therefore be exercised reasonably, on relevant considerations, and in furtherance of that object. A refusal that is arbitrary or unsupported by recorded reasons is vulnerable to challenge. The authority must show independent application of mind and cannot reject the request by a bare or non-speaking order. The availability of inspection and verification powers under the Bihar Finance Act, 1981 also means consolidated registration does not prevent tax administration from performing its statutory functions.

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Issues: (i) whether the Commissioner's refusal to grant consolidated registration under rule 3(4) of the Bihar Sales Tax Rules, 1983 was arbitrary and liable to be quashed; (ii) whether consolidated registration could be refused in the exercise of discretion without recording reasons and without showing consideration of relevant factors.

Issue (i): whether the Commissioner's refusal to grant consolidated registration under rule 3(4) of the Bihar Sales Tax Rules, 1983 was arbitrary and liable to be quashed.

Analysis: Rule 3(4) creates an exception to the general requirement of separate registration for each place of business under rule 3(1). The provision enables consolidated registration where a dealer has more places of business in different circles or sub-circles, and the object is to avoid unnecessary harassment while also serving administrative convenience. The power is discretionary, but that discretion must be exercised reasonably and on relevant considerations in furtherance of the rule's object.

Conclusion: The refusal was arbitrary and liable to be set aside.

Issue (ii): whether consolidated registration could be refused in the exercise of discretion without recording reasons and without showing consideration of relevant factors.

Analysis: An administrative authority exercising statutory power must act independently, fairly, and on lawful grounds. Even where discretion is vested in the authority, the order must show application of mind and must disclose at least some reason indicating why the statutory power was exercised against the applicant. A bare rejection, or one that does not show independent consideration of the relevant material, is vulnerable to challenge. The availability of powers under section 33 of the Bihar Finance Act, 1981 to inspect accounts and verify transactions also meant that consolidated registration would not disable the tax authorities from performing their statutory functions.

Conclusion: The Commissioner was bound to record reasons and could not reject the request without demonstrating independent consideration of the relevant factors.

Final Conclusion: The impugned rejection of consolidated registration was quashed and the matter was sent back for fresh consideration in accordance with law.

Ratio Decidendi: A statutory discretion affecting civil rights must be exercised independently, on relevant considerations, and by a reasoned order; a non-speaking or arbitrary refusal is liable to be struck down.

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