Judgment

BHAGWATI, J.:- I have had the advantage of reading the judgement prepared by my learned brother Sen and I entirely agree with the conclusion reached by him, but I would like to state briefly my own reasons for arriving at that conclusion. The facts giving rise to this appeal have been stated with admirable succinctness by my learned brother Sen and I need not repeat them The facts indeed are not material, because only one single question of law arises for determination in this appeal and it does not depend on any particular facts. The question is a very simple one, namely, whether the expression Registered dealer in Section 8 (ii) of the Bombay Sales Tax Act, 1959 as applicable to the State of Gujarat (hereinafter referred to as the Bombay Act) means only a dealer registered under Section 22 of that Act or it also comprises a dealer registered under the Central Sales Tax Act, 1956 (hereinafter referred to as the Central Act).

2. Since the decision of this question turns on the true interpretation of the expression Registered dealer, in Sec. 8 (ii) of the Bombay Act. we may reproduce that section as follows:

"Section 8: There shall be levied a sales tax on the turn-over of sal