ORDER K. Mohan Ram, J. - By consent of the learned counsel on either side, the writ petitions are taken up for final disposal. Since the facts of all the above four cases are identical and the issue involved is one and the same, a common order is being passed in all the above writ petitions. The petitioners in the respective writ petitions are registered dealers under the Tamil Nadu General Sales Tax Act, 1959 (hereinafter referred to as, "the Act"). Admittedly, the certificate of registration was not renewed by the petitioners within the validity period of one year and hence as per section 21(3) of the Act, the registration certificate of the dealers is deemed to have been cancelled with effect from April 1, 2006. In all the four cases, the petitioners applied for renewal, for the year 2006-07 only on June 13, 2006, by each of them enclosing demand draft for Rs. 1,400 (rupees one thousand four hundred only), all dated June 7, 2006. All the four applications were returned along with the demand drafts by the third respondent herein, by his separate but identical orders dated June 16, 2006, by relying upon section 21(3) of the Act and the decision in N.V.S. Agro Derivatives v. Commercial Tax Officer (Circle I), Theni reported in [2006] 144 STC 106 (Mad). In the said orders, the third respondent has stated that the dealers have not renewed the registration certificate by paying the prescribed fee within the prescribed period, i.e., within April 30, 2006 and so, as per section 21(3) of the Act, the registration certificate is deemed to be cancelled automatically. The third respondent has further stated that registration certificates, which are deemed to have been cancelled, could not be renewed by the subsequent payment of registration fees with penalty. The said orders of the third respondent are being challenged in the above writ petitions. The main contention of the petitioners is that the third respondent before passing the impugned orders should have provided an opportunity of hearing under sections 21(3), 21(5) and 21(6) of the Act. The said orders of the third respondent are being challenged in the above writ petitions. The main contention of the petitioners is that the third respondent before passing the impugned orders should have provided an opportunity of hearing under sections 21(3), 21(5) and 21(6) of the Act. Though no counter-affidavit has been filed by the respondents, the learned Special Government Pleader on written instructions submitted that no notice or opportunity of hearing need be given to the petitioners in view of the provisions contained in section 21(3) of the Act, which provides for deemed cancellation of the registration certificate, if it is not renewed within the prescribed period. Heard both. The learned counsel for the petitioners relied upon the following decisions : (i) Sun Gas Pvt. Ltd. v. Registrar, Tamil Nadu Taxation Special Tribunal reported in [2002] 125 STC 496 (Mad). (ii) Fisher Pumps (P.) Ltd. v. Commercial Tax Officer, Avaramplayam Assessment Circle, Coimbatore reported in [2005] 139 STC 152 (Mad). (iii) C. Baskaran v. Deputy Commercial Tax Officer, Tindivanam Tax Circle, Tindivanam [W.P. No. 2264 of 2006 dated March 13, 2006 - Madras High Court]. and submitted that under sections 21(5) and 21(6) of the Act, an opportunity ought to have been given before returning the renewal application of the petitioners. In the considered view of this court, the facts of all the three cases referred to and relied upon by the learned counsel for the petitioners are different from the cases on hand and therefore the ratio laid down therein is not applicable to these cases. Whereas the facts of these cases and the facts of the case reported in N.V.S. Agro Derivatives v. Commercial Tax Officer, (Circle I), Theni [2006] 144 STC 106 (Mad), which has been relied upon by the third respondent in the impugned orders, are similar. Therefore, the ratio laid down in N.V.S. Agro Derivatives v. Commercial Tax Officer [2006] 144 STC 106 (Mad) squarely applies to the facts of these cases. In N.V.S. Agro Derivatives v. Commercial Tax Officer [2006] 144 STC 106 (Mad) the learned Judge has considered Sun Gas Pvt. Ltd. v. Registrar, Tamil Nadu Taxation Special Tribunal [2002] 125 STC 496 (Mad) and Fisher Pumps (P.) Ltd. v. Commercial Tax Officer, Avaramplayam Assessment Circle, Coimbatore [2005] 139 STC 152 (Mad) and distinguished them by referring to the relevant provisions of the Act. The facts of case in N.V.S. Agro Derivatives v. Commercial Tax Officer reported in [2006] 144 STC 106 (Mad) are as follows : "... the petitioner therein approached the Commercial Tax Officer in the first week of July, 2005 seeking for issuance of form H declarations, they were informed that the petitioner's registration certificates were cancelled under both Acts from April 30, 2003 as the petitioner failed to get the certificate renewed as per the provisions of the Act and on that score refused to issue form H declaration to the petitioner. Thereafter, on July 7, 2005 the petitioner applied for renewal of the registration certificates by paying the necessary fees, but the respondent by the impugned proceedings dated July 11, 2005 returned the fees by stating that the last date for payment of fee for renewal of the registration certificates with penalty for the year 2003-04 was April 30, 2003 and since the petitioner did not pay the renewal fee and apply for renewal within the stipulated period the petitioner's request at this point of time could not be considered." The abovesaid order was challenged and the learned Judge after referring to the provisions contained in section 21(3) of the Act and the relevant Rules, viz., 24(9) and 24(9A) for renewal, held that the order passed by the Commercial Tax Officer returning the application of the petitioner therein cannot be faulted. The facts of these cases are identical to the facts of the case in N.V.S. Agro Derivatives v. Commercial Tax Officer reported in [2006] 144 STC 106 (Mad) as in these four cases also the application for renewal was submitted only on June 13, 2006, i.e., after the deemed cancellation and after the prescribed time-limit of April 30, 2006. Therefore, I am of the considered view that the ratio laid down in N.V.S. Agro Derivatives v. Commercial Tax Officer [2006] 144 STC 106 (Mad) squarely applies to the facts of these cases. The learned counsel for the petitioners by relying upon my order dated March 13, 2006 passed in C. Baskaran v. Deputy Commercial Tax Officer, Tindivanam Tax Circle, Tindivanam [W.P. No. 2264 of 2006 dated March 13, 2006 - Madras High Court] submitted that notice ought to have been given before cancellation of registration. The learned counsel for the petitioners by relying upon my order dated March 13, 2006 passed in C. Baskaran v. Deputy Commercial Tax Officer, Tindivanam Tax Circle, Tindivanam [W.P. No. 2264 of 2006 dated March 13, 2006 - Madras High Court] submitted that notice ought to have been given before cancellation of registration. The said submission overlooks the fact that in these cases, the question of cancellation of registrations does not arise, in view of the deeming provision contained in section 21(3) of the Act and these are not cases where the registration certificates are cancelled by orders passed by the third respondent. In C. Baskaran v. Deputy Commercial Tax Officer [W.P. No. 2264 of 2006], the cancellation order was passed without giving an opportunity of hearing as provided for under section 21(6) of the Act and therefore the said order is not applicable to the facts of these cases. The learned counsel for the petitioners by relying upon section 21(6) of the Act submitted that no renewal under section 21(6) of the Act shall be refused, unless the dealer concerned has been given an opportunity of being heard. Section 21(6) reads as follows : "21(6) No application for registration or for a copy or duplicate of the certificate and no renewal under this section shall be refused and no order under sub-section (5) shall be made, unless the dealer concerned has been given an opportunity of being heard." The learned counsel for the petitioners by relying upon the following words in section 21(6), namely "no renewal under this section shall be refused and no order in sub-section (5) shall be made, unless the dealer concerned has been given an opportunity of being heard", strenuously contended that before refusing to renew the registration, the dealers concerned should be given an opportunity of being heard, since in section 21(6) it is not stated that the application should have been filed on or before 30th April of the year for which renewal is requested. When the attention of the learned counsel was drawn to the provisions contained in section 21(3) and rule 24(9A) of the Tamil Nadu General Sales Tax Rules, 1959 (hereinafter referred to as, "the Rules"), which reads as follows : "Section 21(3) The certificate issued under sub-section (2) shall be valid for one year or five years, as the case may be, and shall be renewed in such manner and within such period as may be prescribed on payment of the fee specified in sub-section (1). The certificate shall be deemed to have been cancelled unless it has been renewed : Provided that a registered dealer who fails to renew the certificate of registration within the prescribed period shall be permitted to renew the certificate before a further period, as may be prescribed, on payment of renewal fee and also a penalty equal to renewal fee." "Rule 24(9A) Notwithstanding anything contained in sub-rule (9), registered dealer who fails to renew the certificate of registration on or before the date specified in that sub-rule shall be permitted to renew the certificate up to 30th day of April for the year for which renewal is requested on payment of a penalty equal to the fee payable for the principal or additional place of business, as the case may be. Provided that in respect of the financial year commencing from the 1st day of April, 2002, every registered dealer shall pay the fee as specified in sub-section (1) of section 21 of the Act on or before the 30th day of April, 2002." the learned counsel submitted that there is a lacuna in section 21(6) of the Act and until and unless an amendment is made to section 21(6) to make it in consonance with the other provisions of the Act and rule 24(9A), an opportunity of hearing is a must before refusing renewal. But, I am unable to accept the said submission of the learned counsel for the petitioners for the reasons set out below : To better appreciate the contention of the learned counsel for the petitioners, it will be useful to refer to the relevant statutory provisions which govern the issue of registration certificate under the Act and the Rules. The relevant section and rules were amended with effect from April 1, 2002. Section 21 of the Act reads as follows : "21. Procedure for registration. The relevant section and rules were amended with effect from April 1, 2002. Section 21 of the Act reads as follows : "21. Procedure for registration. - (1) An application for registration shall be made to such authority, in such manner and within such period as may be prescribed and shall be accompanied by a fee of two thousand and five hundred rupees in respect of public limited companies, one thousand rupees in respect of private limited companies and five hundred rupees in respect of other dealers for the principal place of business, and in addition, a further fee of two hundred rupees in respect of public limited companies, one hundred rupees in respect of private limited companies and fifty rupees in respect of other dealers in respect of each of the places of business other than the principal place of business." Sub-section (2) of the above provision reads as follows : "(2) If the prescribed authority is satisfied that the application is in order and the condition, if any, imposed under sub-section (1A) has been complied with, it shall register the applicant and grant to him a certificate of registration in the prescribed form specifying all his places of business with copies for each of his place of business other than the principal place of business." Sub-section (3) of section 21 reads as follows : "21(3) The certificate issued under sub-section (2) shall be valid for one year or five years, as the case may be, and shall be renewed in such manner and within such period as may be prescribed on payment of the fee specified in sub-section (1). The certificate shall be deemed to have been cancelled unless it has been renewed : Provided that a registered dealer who fails to renew the certificate of registration within the prescribed period shall be permitted to renew the certificate before a further period, as may be prescribed, on payment of renewal fee and also a penalty equal to renewal fee." The relevant rule applicable in the case of renewal is rule 24(9) and 24(9A) : "Rule 24(9) Every registered dealer shall, until his registration is cancelled, submit an application in form 'D' and pay the fee as specified in sub-section (1) of section 21 of the Act for every year subsequent to that in which he applied for registration, during the month of March of the financial year for which the registration is valid and in addition a further fee as in sub-section (1) of section 21 in respect of each of his place of business other than the principal place of business. Every person signing and verifying an application in form 'D' shall also furnish with the application two copies of his recent photograph in passport size, if such photographs had not been furnished earlier." The challan or other proof of payment of the renewal fee shall be sent to the registering authority along with the application in form D. The registering authority, on receipt of application for renewal along with proof of payment of the renewal fee, shall make such enquiry or cause such enquiry to be made, as it may consider necessary and renew, modify or cancel the registration certificate. Where the renewal is made, the registering authority shall inform the dealer that his registration has been renewed and the dealer shall have such information filed along with his registration certificate. Where the renewal of registration is proposed to be modified or rejected, the registering authority shall do so after giving a reasonable opportunity to the dealer to show cause against such modification or rejection. Where the renewal of registration is proposed to be modified or rejected, the registering authority shall do so after giving a reasonable opportunity to the dealer to show cause against such modification or rejection. If such intimation or renewal is not received by the applicant within thirty days from the date of his application or if no notice giving him an opportunity of being heard is received by him within the said period, the applicant shall be deemed to have been duly registered : Provided also that in respect of the financial year commencing from the 1st day of April, 2002, a registered dealer who fails to renew the certificate of the registration on or before the date specified in sub-rule (9) shall be permitted to renew the certificate up to 30th day of September, 2002 on payment of a penalty as specified; Rule 24(9A) has already been extracted above. As per the above provisions, the conditions or requirements for renewal of the registration certificate are as follows : 1. The registration certificate is valid for one year for dealers like the petitioners and five years for companies. 2. The dealers have to submit renewal applications in form "D". 3. Along with the applications, proof of payment of renewal fee as specified in section 21(1) has to be sent. 4. Applications for renewal and payment of fee as aforesaid in clauses (1) and (2) have to be made every year during the month of March of the financial year for which the registration certificate is valid. 5. The dealers who fails to renew the certificate of registration on or before the month of March of the financial year for which registration certificate is valid could renew the registration certificate up to 30th April of the year for which the renewal is requested on payment of registration fee as specified in section 21(1) with the penalty equal to the registration fees. 6. The registration certificate shall be deemed to have been cancelled unless it has been renewed. In this context, it is relevant to point out that proviso to sub-rule (9), the second proviso to that sub-rule, sub-rule (9A), and proviso to that sub-rule are all amended or added by Notification No. SRO.A-29(b-2)/2002 dated June 27, 2002, effective from July 1, 2002, to accord with the amended section 21 of the Act. In this context, it is relevant to point out that proviso to sub-rule (9), the second proviso to that sub-rule, sub-rule (9A), and proviso to that sub-rule are all amended or added by Notification No. SRO.A-29(b-2)/2002 dated June 27, 2002, effective from July 1, 2002, to accord with the amended section 21 of the Act. Since the amendments were given effect to from July 1, 2002 to avoid hardship to the registered dealers and to give effect to the amended provisions in the third proviso to rule 24(9) of the Rules, it is provided that in respect of the financial year commencing from the first day of April, 2002, registered dealers who fail to renew the certificate of the registration on or before the date specified in sub-rule 24(9) shall be permitted to renew the certificate up to 30th day of September, 2002 on payment of a penalty as specified. But for the subsequent years, namely, from the financial year commencing from first day of April 2003, no such extended period is provided for. The dealers who fail to renew the certificate of registration on or before the month of March of the financial year for which registration certificate is valid could renew the registration certificate up to 30th April of the year for which the renewal is requested on payment of registration fee as specified in section 21(1) with the penalty equal to the registration fees as pointed out above. As per section 21(3) of the Act, the certificate shall be deemed to have been cancelled unless it has been renewed and the registered dealers who fail to renew the certificate within the prescribed period are permitted to renew the certificate before a further period as may be prescribed on payment of renewal fee and also a penalty equal to renewal fee. Therefore the registered dealers are permitted to get the renewal before a further period as may be prescribed and as per rule 24(9A), the further period prescribed is up to 30th day of April of the year for which the renewal is requested on payment of a penalty equal to the fee payable for the principal or additional place of business, as the case may be. Therefore, it is crystal clear from a conjoint reading of all the abovesaid provisions that if an application for renewal is made within time and if the registering authority chooses to refuse the renewal, then it is mandatory for the authority to give an opportunity of hearing to the dealer. Section 21(6) will not apply to a case where the renewal application is submitted after 30th April of the year for which the renewal is sought for. But, in all these four cases, admittedly the renewal applications were not filed in time, but were filed beyond the time prescribed under the Act and therefore the question of affording an opportunity of hearing does not arise. The provisions of the Act and Rules have to be read together and should be construed harmoniously, but should not be read in isolation as is sought to be done by the learned counsel for the petitioner, which if done will be against the principle of statutory interpretation. Admittedly in these cases the renewal applications were submitted after April 30, 2006 namely on June 13, 2006. Therefore, in my considered view the question of giving an opportunity of hearing to the petitioners does not arise and hence the submission of the learned counsel for the petitioner is not acceptable. For the foregoing reasons, all the four writ petitions fail and accordingly they are dismissed. However, there will be no order as to costs. Consequently, the connected miscellaneous petitions are closed.