Judgement

VENKATARAMA AIYAR, J. : The sole point for determination in this appeal which is directed against the Judgment of the High Court of Bombay, is whether the appellant is not liable to pay tax under the provisions of the Central Provinces and Berar Sales Tax Act, 1947 (Act 21 of 1947), on the ground alleged that it had not been validly registered as a dealer under S. 8 of the Act. The facts bearing on his contention are that the Central Provinces and Berar Sales Tax Act, hereinafter referred to as "the Act", received the assent of the Governor-General on May 23, 1947 and came into force on June 1, 1947. On May 27, 1947 a notification No. 601 was issued by the Provincial Government publishing draft rules which it "proposed to make, in exercise of the powers conferred by S. 28 of the Act" and on August 15, 1947, the rules as finally adopted were published. In the meantime two other notifications Nos. 597 and 599 had been issued on May 27, 1947, No. 597 under S. 8 of the Act fixing August 15, 1947 as "the date by or on which all dealers liable to pay tax under the said Act shall get themselves registered" and No. 599 under S. 3 of the Act appointing the District Excise Officers