Tax liability depends on the charging provision; invalid registration or procedural defects do not defeat assessment jurisdiction.

Liability to sales tax arose from the charging provision and was not made conditional on valid registration under section 8. The registration requirement governed dealer compliance and assessment procedure, but it did not affect the substantive tax liability created by the Act. An invalid registration certificate, even if assumed, did not deprive the taxing authorities of jurisdiction where their power to assess otherwise existed under the Act. A defect in the mode of assuming jurisdiction was only an irregularity and did not make the assessment a nullity open to collateral challenge. The challenge to the assessments therefore failed, and the civil suit was also barred by the statutory exclusion of civil court jurisdiction.

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Issues: Whether a dealer's liability to pay sales tax could be disputed on the ground that its registration under section 8 was invalid, and whether any defect in the assessment procedure deprived the taxing authorities of jurisdiction.

Analysis: The liability to pay tax arose under the charging provision in section 4 and was not made conditional upon registration under section 8. The registration requirement regulated business as a dealer and the assessment procedure, but did not affect the substantive liability created by the Act. Even if the registration certificate was invalid, the assessment proceedings were not without jurisdiction. Section 10 governed procedure for returns and notices, while the authorities derived jurisdiction to assess from sections 3 and 11. A defect in the mode of assumption of jurisdiction would at most be an irregularity and would not render the assessment a nullity open to collateral challenge. The suit also faced the bar on civil court jurisdiction under section 21.

Conclusion: The challenge to the assessments failed. Invalidity of registration, even if assumed, did not absolve liability to tax or invalidate the assessment proceedings.

Ratio Decidendi: Liability under a taxing statute depends on the charging provision, and a procedural defect or invalid registration does not negate substantive tax liability or render assessments without jurisdiction where the authority otherwise has power to assess.

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