Dealer registration under central sales tax cannot rest on a state law amendment alone without independent statutory satisfaction.

Liability to register as a dealer under the Central Sales Tax Act must be determined independently under that Act, and cannot be created solely by an amendment to the definition of turnover in the Tamil Nadu General Sales Tax Act. The court noted that the local amendment did not correspond to any change in the Central Sales Tax Act, and that there was no independent material showing the petitioner's members satisfied the dealer requirements under the central law. Mere ownership of plantations and sale of produce was not enough without proof of business activity with the necessary profit-motive in inter-State trade. Compulsory registration was therefore not justified on the basis of the state amendment alone, though individual cases could still be proceeded with on proper facts.

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Issues: Whether the respondents could compel the petitioner's members to register as dealers under the Central Sales Tax Act, 1956 solely on the basis of an amendment to the definition of turnover in the Tamil Nadu General Sales Tax Act, 1959.

Analysis: The operative legal position was that liability under the Central Sales Tax Act had to be tested only by reference to that Act. The judgment noted that although section 2(r) of the Tamil Nadu General Sales Tax Act, 1959 had been amended, there was no corresponding amendment to the Central Sales Tax Act. The earlier decisions relied on had recognised that mere ownership of plantations and sale of produce, without proof of business activity with profit-motive in inter-State trade, was not enough by itself to establish dealer status under the Central Sales Tax Act. The respondents had no independent material showing that the petitioner's members were dealers under that enactment, and a local amendment could not authorise compulsory registration under the Central Sales Tax Act.

Conclusion: The respondents could not lawfully compel registration under the Central Sales Tax Act merely on the strength of the amendment to the Tamil Nadu General Sales Tax Act, 1959. The writ petition succeeded, while liberty was reserved to proceed in individual cases on proper material.

Final Conclusion: The impugned demand for registration was quashed, with the authority of the department preserved only for action on a case-by-case basis where facts justify treating an individual planter as a dealer.

Ratio Decidendi: Compulsory registration as a dealer under the Central Sales Tax Act can be imposed only when the statutory requirements of that Act are independently satisfied, and a State law amendment cannot by itself extend that liability.

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