S. P. BHARUCHA, C. J. ( 1 ) THE Revision Petition requires us to construe Section 5 (2) of the karnataka Sales Tax Act, 1957 (the Karnataka Act' for short) which reads:"notwithstanding anything contained in sub-section (5), a dealer registered under the Central Sales Tax Act, 1956, shall, whatever be the quantum of his total turnover, be liable to pay tax at the rate specified in this Act on the sale of any goods which he has purchased in the course of inter-State trade or commerce in respect of which the concessional rate of tax under clause (b) of sub-section (1) of Section 8 of the Central Sales Tax Act, 1956, has been levied. " ( 2 ) THE petitioner purchased goods in the course of inter-State trade availing of the concessional rate of tax under Section 8 (1) (b) of the central Sales Tax Act, 1956 ('the Central Act' for short ). He did so in the course of the assessment year 1980-81, during which period he was registered as a dealer under the Central Act. He sold these goods during the assessment year 1981 - 82, by which time he had his registration as a dealer under the Central Act cancelled. It was his contention before the authorities below that he was not liable to pay tax at the rate specified in the Karnataka Act on the sale of such goods during the assessment year 1981 -82 because i) he was not registered as a dealer under the Central act during that period, and ii) because his turn-over fell below the minimum specified in the Karnataka Act. His contentions were rejected. The Karnataka Appellate Tribunal took the view that Section 5 (2) did not specifically say that the dealer should be a registered dealer under the central Act during the period of assessment. ( 3 ) AS we read Section 5 (2) of the Karnataka Act it requires: a) that the dealer must be registered under the Central Act; b) that he had purchased, in the course of inter-State trade or commerce, goods in respect of which the concessional rate of tax under Section 8 (1) (b) of the central Act had been levied; and c) that he had sold those goods. The sub-section also states that he shall be liable to pay tax as specified in the Karnataka Act upon such goods upon their sale "whatever be the quantum of his total turnover". ( 4 ) HAVING regard to the fact that the dealer is required to pay tax upon sale of such goods under the Karnataka Act "whatever be the quantum of his total turn-over", the contention on behalf of the petitioner that he is not liable to pay the tax because his turn-over falls short of the minimum prescribed by the Karnataka Act must be rejected. ( 5 ) HOWEVER, we find substance in the contention that the petitioner is not liable to pay tax under Section 5 (2) because, for the relevant assessment year, he was not a dealer registered under the Central Act. In our view, the words " a dealer registered under the Central Sales Tax act, 1956," mean a dealer who is at the time of the sale of the goods registered as a dealer under the Central Act. We are unable to accept the submission on behalf of the Sales Tax Authorities that these words must mean that the dealer should have been registered under the central Act when he purchased the goods. The provision contemplates the levy of tax upon goods which have been purchased in the course of the inter-State trade and in respect of which concessional rate of tax under the Central Act has been levied. This necessarily implies that the dealer should have been registered under the Central Act when he purchased the goods. The words " a dealer registered under the Central sales Tax Act, 1956" must, therefore, refer to the point of time when he sold the goods. ( 6 ) HAVING regard to this interpretation of the provisions of Section 5 (2) of the Karnataka Act, we must set aside the order of the Tribunal and hold that the petitioner was not liable to pay any tax under the provisions of Section 5 (2) of the Karnataka Act for the Assessment year 1981- 82 in respect of the goods purchased by him during the assessment year 180-81 at a concessional rate under the Central Act. Ordered accordingly. No order as to costs. --- *** --- .