JUDGMENT : ( 1. ) THIS is a reference under section 44 of the Madhya pradesh General Sales Tax Act, 1958 made by the Board of Revenue at the instance of Commissioner of Sales Tax to obtain the opinion of this Court on the following questions, namely :- (a) Whether the assessee M/s Laxman Chhotelal should be allowed to claim deduction under section 2 (r) (ii) with retrospective effect, namely, from the date the registration certificate of the seller M/s General suppliers was given effect; and (b) Whether if the seller is assessed for the unregistered period under section 18 (6), in respect of the sales to the purchaser during such period also, the purchaser should be allowed exemption from purchase tax on the ground that the Act contemplated only a single point levy. ( 2. ) THE assessee non-applicant was a dealer and was engaged in executing construction works. During the period between 1-4-1965 and 31-3 1966, the assessee purchased road metal (Gittis) and Murram from M/s General suppliers, Ujjain. By an order dated 3-1-1967, the Sales Tax Officer held the assessee liable to pay purchase tax under section 7 of the Madhya Pradesh general Sales Tax Act on the price of the material thus purchased from m/s General Suppliers, Ujjain. At the time of assessment, the firm of M/s general Suppliers, Ujjain was not registered as a dealer under the Act. Subsequently, in proceeding instituted under section 18 (6), M/s General suppliers, Ujjain were held to be liable to pay sales tax with effect from 1-10-1964. The order of the Sales Tax Officer holding M/s General Suppliers liable was passed on 17-4-1967. The assessee preferred an appeal before the Appellate Assistant Commissioner, Sales Tax claiming that since M/s general Suppliers, Ujjain have been held to be liable to pay tax with effect from 1-10-1964 and that they had been registered with effect from that date, the General Suppliers have been assessed to sales tax on transactions made with them including the impugned turnover on which the assessee has been levied purchase tax. The Assistant Commissioner, Sales Tax, rejected the contention on the ground that on the date of assessment, M/s General suppliers, Ujjain were not registered and, therefore, they had been rightly held to be liable to pay purchase tax under section 7 (1) of the Act. The Assistant Commissioner, Sales Tax, rejected the contention on the ground that on the date of assessment, M/s General suppliers, Ujjain were not registered and, therefore, they had been rightly held to be liable to pay purchase tax under section 7 (1) of the Act. The assessee preferred a second appeal before the Board of Revenue which by its order dated 16-6-1969 held that the purchase tax could not be levied on the assessee as the selling dealer, namely, M/s General Suppliers, Ujjain had been charged the sales tax on the transaction of sale. The tax, it was observed, could be levied only at one stage and at one point and the same transaction could not be subjected to a purchase tax as also a sales tax. It was also observed that the Assistant Appellate Commissioner should have considered the objection of the assessee that the sales tax had been paid by the purchasing dealer on the transaction and, therefore, purchase tax could not be levied on him. The above order has given rise to the two questions referred now. ( 3. ) UNDER the definition of taxable turnover a sale made by a registered dealer to another registered dealer is exempted under section 2 (r) (ii) of the Act. Section 2 (r) (ii) reads as under :- "2 (r) taxable turnover in relation to any period means that part of a dealers turnover for such period which remains after deducting therefrom- (i ). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . (ii) Sale price of goods mentioned in Parts II to VI of Schedule II which have been purchased otherwise than in the course of inter-State trade or commerce from a registered dealer, provided that the sale of such goods by such registered dealer were taxable under the Act. " By section 10 of the Amendment Act, this clause has been given effect to from 15th August 1962. It is clear that if exemption could be claimed under section 2 (r) (ii), no purchase tax under section 7 (1) could be levied. Section 7 (1) reads as under:- "7. " By section 10 of the Amendment Act, this clause has been given effect to from 15th August 1962. It is clear that if exemption could be claimed under section 2 (r) (ii), no purchase tax under section 7 (1) could be levied. Section 7 (1) reads as under:- "7. Levy of purchase tax.- (1) Every dealer who in the course of his business purchases any taxable goods from a registered dealer in circumstances in which no tax under section 6 is payable on the sale price of such goods or from any other person and either consumes such goods in the manufacture of other goods for sale or otherwise or disposes of such goods in any manner other than by way of sale in the State or despatches them to a place outside the State except as a direct result of sale or purchase in the course of inter-State trade or commerce or disposes of such goods under compulsory levy in pursuance of the provision of any Central or State law for the time being in force or any order, rule or notification made thereunder shall be liable to pay tax on the purchase price of such goods at the same rate at which it would have been leviable on the sale price of such goods under section 6; provided that no tax under this section shall be levied in respect of any year on- (a) a dealer in cooked food including sweets and sweet-meats, mishri, batasha, chironji, Shrikhand, rabdi, doodpak but excluding ice-cream, kulfi, ice-candy, non-alcoholic drinks containing ice-cream, cakes, pastries; biscuits, chocolates, toffees lozenges and peppermint drops, if the aggregate of purchase prices of all goods does not exceed fifteen thousand rupees; (b) any other dealer, if the aggregate of purchase prices of all goods does not exceed seven thousand five hundred rupees. " ( 4. ) THE assessee had purchased goods from M/s General Suppliers, ujjain who, at the relevant time were not registered dealers under the Sales tax Act. The assessee utilised the goods in construction of a road and obviously they had not been re-sold in Madhya Pradesh. He therefore; became liable to pay tax on the purchase price of Gitti and Murram. It turned out that M/s General Suppliers, Ujjain had become liable to pay sales tax with effect from 1-10-1964. The assessee utilised the goods in construction of a road and obviously they had not been re-sold in Madhya Pradesh. He therefore; became liable to pay tax on the purchase price of Gitti and Murram. It turned out that M/s General Suppliers, Ujjain had become liable to pay sales tax with effect from 1-10-1964. Despite the fact that M/s General Suppliers, ujjain have been assessed for the unregistered dealers in so far as the impugned sales to the assessee were concerned. The essential requirement for exemption under section 2 (r) (ii) is that the selling dealer (assessee) must have purchased the goods from a registered dealer. Under section 15 (9), if any dealer is required to pay the amount of penalty imposed under sub-section (5) or sub-section (6) of section 18, or is convicted or pays composition money under section 47 in respect of any contravention of sub-section (1)or sub-section (2), the Commissioner is enjoined to register such dealer and grant him a certificate of registration but such registration will take effect from the date of issue of certificate as though it had been granted under subsection (4) on the dealers application. Even under sub-section (9) of section 15, it is after the grant of registration certificate that the dealer becomes a registered dealer. The registration does not take effect from the time the liability to pay tax arises under the above section but only after the issuance of the registration certificate. Though registration of a dealer is and incidence of the liability to pay tax under the Act, the scheme clearly is that the registration takes effect after the grant of a registration certificate. Section 2 (r) (ii) therefore, in our opinion, would not be attracted to avail him the exemption from the purchase tax in the circumstances of the case. ( 5. ) WE would then come to the second proposition, namely, whether m/s General Suppliers, Ujjain having paid sales tax on the impugned sales of Gitti and Murram, was it legal to charge purchase tax from the assessee. In effect, on the same transaction a purchase and a sales-tax have been charged. However, though the result appears a little startling, this is because of the peculiar circumstances of the case. In effect, on the same transaction a purchase and a sales-tax have been charged. However, though the result appears a little startling, this is because of the peculiar circumstances of the case. There is nothing expressly stated under the Act or under the rules that a double taxation was prohibited or could not be imposed under the Sales Tax Act. But it is so stated that upon general words of taxation, when a Taxation Act is to be interpreted you cannot so interpret it so as to tax the subject twice over to the same tax, See, attorney General v. London County Council (5 T C 242 at p. 260) and Madanlal Dharnidharka v. C. I. T. (1948 I T R 227 at p. 236 ). We have, however, to be guided by the express language of the taxing statute. In a taxing statute one has to look merely at what is clerly said. There is no room for any intendment. There is no equity about a tax. Nothing is to be read in, nothing is to be implied. One can only look fairly at the language used See C. I. T. v. Shahzada Nand and Sons ( (1966) 60 I T R 392 ). Under the sales Tax Act, registration of a dealer has an important place and its scheme works mostly through the medium of a registered dealer. The Act attempts to achieve that neither the same transaction nor the same goods are taxed twice and this is achieved when a registered dealer makes a sale to another registered dealer. But the moment the registered dealer is dealing with the non-registered dealer or with a consumer the course is broken and the activity at that stage is not protected by any provision exempting it from tax. ( 6. ) AS already discussed above, when the assessee purchased the goods from a non-registered dealer under the circumstances which attracted purchase tax, he could not be heard to say that eventually a sales tax has also been paid on the same transaction by the non-registered dealer in subsequent proceedings. This was because M/s General Suppliers, Ujjain were eventually registered. At the relevant time, they were un-registered dealers. This was because M/s General Suppliers, Ujjain were eventually registered. At the relevant time, they were un-registered dealers. M/s General Suppliers, Ujjain were assessed to sales tax because they had exceeded the taxable quantum and became liable to pay sales tax under section 4 of the Madhya Pradesh General Sales Tax Act with effect from 1-10-1964. As there is no express provision for claiming exemption under the Sales Tax Act, in such situation, no refund could be claimed. As regards the exigibility to purchase tax by the assessee, even if M/s General Suppliers ujjain were assessed for the non-registered period, it would make little difference as far as the liability of the petitioner was concerned. Since the point is not before us, we need not decide it. We, therefore, think that the board of Revenue is not right in holding that the purchase tax could not be levied on the assessee in the circumstances of the case. ( 7. ) OUR answer to both the questions referred is in the negative. The assessee became liable to pay tax and was not entitled to exemption either under section 2 (r) (ii) or because the selling dealer was assessed under section 18 (6) of the Sales Tax for the same period including the impugned transaction on which purchase tax has been levied on the petitioner. We therefore, allow this reference. In the circumstances of the case, there shall be no order as to costs. Reference allowed.