JUDGMENT U. L. BHAT, C.J. - The following question of law has been referred to this Court by the Appellate Tribunal (Board of Revenue) at the instance of the Revenue under section 44(1) of the M.P. General Sales Tax Act, 1958 (for short, "the Act") : "Whether under the facts and in circumstances of the case, the Board of Revenue was justified in holding the goods to be tax-paid ?" 2. The dispute relates to certain sales during the period November 6, 1972 to October 26, 1973 of tendu leaves effected by the assessee, a registered dealer. The goods were originally purchased in Government auction by Rajendrakumar Bakarbhai Patel who was then an unregistered dealer who paid sales tax at ordinary rate on that occasion. Rajendrakumar sold the goods to the assessee. Even at that time Rajendrakumar was an unregistered dealer. In other words, though the assessee is a registered dealer, he made purchases from an unregistered dealer who, in his time, paid sales tax. The question is whether sale price on these goods is to be deducted from the taxable turnover. The first appellate authority held in favour of the Revenue, but the Appellate Tribunal held in favour of the assessee. At the instance of the Revenue, the question of law has been referred. 3. The resolution of the dispute depends on the interpretation of section 2(r)(ii) of the Act as it existed at the relevant time. The provision reads as follows : "2(r). 'Taxable turnover' in relation to any period means that part of a dealer's turnover for such period which remains after deducting therefrom - (i) ................ (ii) the sale price of goods mentioned in Parts II to VI of Schedule II, other than paddy and whole pulses which have been purchased otherwise than in the course of inter-State trade or commerce from a registered dealer, provided that the sales of such goods by such registered dealer, were taxable under the Act." 4. Tendu leaves find place in Part II of Schedule II. Therefore, the goods, sale price of which is under consideration, are goods mentioned in Part II and covered by section 2(r)(ii). The goods have been purchased otherwise than in the course of inter-State trade or commerce. The purchases were effected not from a registered dealer, but from an unregistered dealer. Tendu leaves find place in Part II of Schedule II. Therefore, the goods, sale price of which is under consideration, are goods mentioned in Part II and covered by section 2(r)(ii). The goods have been purchased otherwise than in the course of inter-State trade or commerce. The purchases were effected not from a registered dealer, but from an unregistered dealer. A Division Bench of this Court, in Commissioner of Sales Tax, M.P. v. Laxman Chhotelal Ujjain (1979) 12 VKN 253, held that dealer from whom the assessee made the purchases, should be a registered dealer and if he is not a registered dealer, section 2(r)(ii) will not apply and the turnover is not to be deducted for reckoning taxable turnover. It was argued before the court that the provision reflects the principle of single point tax and, therefore, whether the dealer from whom the assessee purchased is registered or not, is not relevant and what is relevant is whether somewhere along the line of transactions, a registered dealer has paid the tax. The Division Bench rejected this contention on the ground that in a taxing statute, one has to look merely at what is clearly said, and there is no room for any intendment and there is no equity about tax. Nothing is to be read in nothing is to be implied. 5. The Appellate Tribunal placed reliance on the decision of the Supreme Court in State of Punjab v. Mulakh Raj Nand Lal [1982] 50 STC 101. The Supreme Court considered the language used in section 5(1-A) and the proviso thereto of the Punjab General Sales Tax Act, 1948. Section 5(1-A) and the proviso read as follows : "5. Rate of tax - (1) .................... The Supreme Court considered the language used in section 5(1-A) and the proviso thereto of the Punjab General Sales Tax Act, 1948. Section 5(1-A) and the proviso read as follows : "5. Rate of tax - (1) .................... (1-A) The State Government may by notification, direct that in respect of such goods other than declared goods, and with effect from such date as may be specified in the notification, the tax under sub-section (1) shall be levied at the first stage of sale thereof, and on the issue of such notification the tax on such goods shall be levied accordingly : Provided that no sale of such goods at a subsequent stage shall be exempt from tax under this Act unless the dealer effecting the sale at such subsequent stage furnishes to the assessing authority in the prescribed form and manner a certificate duly filled in and signed by the registered dealer, from whom the goods were purchased." The tenor of the language would suggest that the certificate is to be produced from a registered dealer from whom the assessee purchased the goods. The Supreme Court held : "........ The dominant intention of section 5(1-A) is to impose the levy of a single point tax on the first stage of the sale of the goods specified in the notification issued thereunder. The charging provision is to be found in section 5(1-A) while the proviso merely provides that subsequent sales will be exempt provided the dealer effecting such subsequent sales furnishes the documents (certificate) mentioned therein. It is not possible to accept the contention on behalf of the State Government that the respondent-assessee having purchased the goods from two unregistered dealers is not entitled to have his sales to his consumers exempted from sales tax. Admittedly, the manufacturer, himself a registered dealer, when he sold the goods to the unregistered dealers had issued the necessary certificates and had undertaken the liability to pay sales tax on the sales effected by him - such sales being the sales at the first stage under clause (b) of the notification dated March 30, 1966. The respondent-assessee had produced the certificates to support his claim that he was not liable to pay any sales tax on the sales effected by him of the very goods to his consumers, the same being claimed as subsequent sales effected by him. The respondent-assessee had produced the certificates to support his claim that he was not liable to pay any sales tax on the sales effected by him of the very goods to his consumers, the same being claimed as subsequent sales effected by him. In our view, the Division Bench of the High Court rightly held that the respondent's sales to his consumers being subsequent sales would not suffer any sales tax." The court further observed : "It is difficult to accept the contention that the phrase 'registered dealer from whom the goods were purchased' occurring at the end of the proviso should be construed so as to prevent the assessee's sales being regarded as subsequent sales simply because his purchases were not from immediate registered dealer but were from two unregistered dealers who had purchased from the registered dealer. The words in that phrase are not 'registered dealer from whom he (the dealer effecting the subsequent sales) had purchased the goods'. The words as they are have been rightly construed by the Division Bench of the High Court to mean a registered dealer 'from whom the goods were (originally) purchased' or 'from whom the goods were purchased (at the first stage)'. Such construction is in consonance with the dominant intention of the Legislature to impose a levy on the sale at the first stage." 6. The above decision shows that since the provision incorporated the principle of single point sales tax, the Supreme Court interpreted the words "registered dealer from whom the goods were purchased" in consonance with the principle of single point sales tax. It was for this reason that it was held that the dealer from whom the assessee purchased himself, was a registered dealer, provided the dealer from whom the goods were purchased at the first stage, was a registered dealer under section 2(r)(ii) of the Act in question. In this case also the words (after omitting the unnecessary words) are "sale price of goods which have been purchased from a registered dealer". Section 2(r)(ii) reflects the principle of single point sales tax and reading the provision in consonance with this principle, it must follow that the registered dealer need not be the dealer from whom the assessee purchased the goods, but could be the dealer from whom the goods were originally purchased or were purchased at the First stage. Section 2(r)(ii) reflects the principle of single point sales tax and reading the provision in consonance with this principle, it must follow that the registered dealer need not be the dealer from whom the assessee purchased the goods, but could be the dealer from whom the goods were originally purchased or were purchased at the First stage. The decision in Laxman Chhotelal's case (1979) 12 VKN 253 cannot be regarded as laying down good law in view of the subsequent decision of the Supreme Court in Mulakh Raj Nand Lal's case [1982] 50 STC 101. 7. The question is answered in the affirmative, i.e., in favour of the assessee and against the Revenue. 8. A copy of this order under the signature of the Registrar and seal of the High Court be transmitted to the Board of Revenue. Reference answered in the affirmative.