JUDGMENT B. N. MAHAPATRA J. - In both the writ petitions, the petitioner is same and has challenged the order dated December 16, 2004 (annexure 3) passed by opposite party No. 2, Additional Commissioner of Sales Tax, South Zone, Berhampur (hereinafter referred to as, "the revisional authority") in Revision Case Nos. PU-216 and 217 of 2000-01 by which the revisional authority refused the petitioner's prayer to issue direction for restoration of the registration certificates of the petitioner which were earlier granted under the Orissa Sales Tax Act, 1947 (hereinafter referred to as, "the OST Act") and Central Sales Tax Act, 1956 (hereinafter referred to as, "the CST Act") and subsequently cancelled by opposite party No. 3, Sales Tax Officer (hereinafter referred to as, "the STO") vide annexure 2, on the ground that the STO has illegally cancelled the registration certificates with retrospective effect without affording due opportunity of hearing to the petitioner. Since the issues involved in both the petitions are same, with consent of the parties, they are heard together and disposed of by this common judgment. Shorn of unnecessary details, the relevant facts and circumstances giving rise to these writ petitions are that the petitioner is a small-scale industrial unit having permanent registration No. 151502135 issued by the District Industries Centre, Bhubaneswar. It carries on business of processing and benefaction of mineral ores. The petitioner was registered under section 9A of the OST Act bearing registration certificate No. BH-II-1229 with effect from December 3, 1992 and under the CST Act bearing Registration Certificate No. BHC-11-849. The petitioner had been filing returns regularly and its registration certificate had been renewed every year till 1998-99. For the year 1999-2000, the petitioner had applied for renewal of registration certificate in prescribed form IIA of the Orissa Sales Tax Rules, 1947 (hereinafter referred to as, "the OST Rules") on April 12, 1999 with a petition for condonation of delay caused in making application for such renewal. The STO cancelled the said registration certificate of the petitioner on December 30, 1999 under section 9(6)(b) of the OST Act with effect from April 1, 1999 on the ground of filing "nil" return for last three consecutive years. The STO also cancelled the registration certificate issued under the CST Act on February 23, 2000 under section 7(4)(b) of the CST Act with effect from April 1, 1999 on similar ground. The STO also cancelled the registration certificate issued under the CST Act on February 23, 2000 under section 7(4)(b) of the CST Act with effect from April 1, 1999 on similar ground. Being aggrieved by the orders of cancellation of registration certificates, the petitioner approached the revisional authority for a direction to the STO for restoration of its registration certificates in Revision Case No. PU-216 of 2000-01, but the same was rejected by the revisional authority as being devoid of any merit. Hence, this writ petition. Mr. N. Paikray, learned counsel appearing on behalf of the petitioner, submitted that the registration certificates of the petitioner were cancelled without complying with the principles of natural justice. No show-cause notice before cancellation of the registration certificates was served on any of the partners of the firm. The opposite party No. 3 has no authority/jurisdiction at the relevant time to cancel the said registration certificates. The revisional authority did not consider the grounds of submission made before it even though the revision petition was kept pending for a long period. The registration certificate granted under section 9A cannot be cancelled under section 9(6)(b) of the OST Act. It can only be cancelled under section 9(6)(a) of the OST Act. Cancellation of registration certificate under the OST Act prior to cancellation of the registration certificate under the CST Act is illegal. Cancellation of registration certificate under the CST Act is also not in accordance with law. Cancellation of registration certificates with retrospective effect is also not permissible under law. In support of his submissions, he placed reliance on some judicial pronouncements. Mr. Dalei, learned counsel appearing on behalf of the Revenue, submitted that the petitioner itself has admitted that during the three consecutive financial years 1996-97, 1997-98 and 1998-99 there was no transaction of purchase or sale and the petitioner filed "nil" returns for those three years both under the OST Act and the CST Act. This being the factual position, no illegality has been committed by the STO in cancelling the registration certificates issued to the petitioner under the OST Act and the CST Act so also the revisional authority is fully justified in upholding the action of the STO. He further submitted that the authority granting registration certificate has the power to cancel the same as per section 22 of the General Clauses Act. He further submitted that the authority granting registration certificate has the power to cancel the same as per section 22 of the General Clauses Act. Rules 6, 6A and 7 of the OST Rules, which deal with grant of registration certificate, authorise the STO to act as prescribed authority, and the cancellation of registration certificates vide annexure 6 was done by him by way of abundant caution. The revisional authority has also passed a reasoned order upholding the action of the STO. The contention of the petitioner that no power has been delegated to the STO to cancel its registration certificate at the relevant time was neither raised before the revisional authority nor has any such pleading been taken in any of the writ petitions. Therefore, at this stage, such plea should not be entertained by this court. It was further argued that opposite party No. 3 served notice bearing No. 9307 dated May 26, 1999 to show cause as to why the registration certificates should not be cancelled under section 9(6)(b) of the OST Act. As the dealer did not file any show cause within the time provided, again another notice bearing No. 16153 dated September 1, 1999 was issued to the petitioner by opposite party No. 3 directing him to file show cause by September 10, 1999 in which it was indicated that in case the petitioner would fail to submit any show cause, his registration certificate would be cancelled with effect from April 1, 1999. In response to the second show-cause notice, the petitioner also did not submit any show-cause reply. Therefore, the impugned order was passed. Similarly, before cancellation of the registration certificate under the CST Act, even though show-cause notice bearing No. 23751 dated December 31, 1999 was served, the petitioner did not respond to the said show-cause notice. It was further argued that proviso to sub-section (2) of section 9A makes it clear that if the prescribed authority is satisfied that the applicant is liable to pay tax under section 4, he shall grant him a registration certificate under section 9 notwithstanding the fact that the application has been made for voluntary registration under sub-section (1). It is not the case of the petitioner that after grant of registration certificate under section 9A of the OST Act it had never become liable to pay tax under section 4 of the OST Act. It is not the case of the petitioner that after grant of registration certificate under section 9A of the OST Act it had never become liable to pay tax under section 4 of the OST Act. In such a fact-situation, it cannot be said that section 9(6)(b) has no application to the case of the petitioner. Otherwise also, since the gross turnover of the dealer for three consecutive years all together was nil, certificate of registration is liable to be cancelled under section 9(6)(a) of the OST Act. It was also argued that the petitioner nowhere in the writ petitions has stated as to how it has been prejudiced by retrospective cancellation of registration certificate. The petitioner has nowhere stated that it has effected any inter-State transaction even after cancellation of its registration certificate under the OST Act making it liable to pay tax under the CST Act. Hence, it is immaterial if the registration certificate under the OST Act has been cancelled prior to cancellation of registration certificate under the CST Act. Mr. Paikray, learned counsel for the petitioner, has advanced several grounds challenging the orders of the STO by which registration certificates of the petitioner have been cancelled under section 9(6)(b) of the OST Act and section 7(4)(b) of the CST Act with effect from April 1, 1999. But the fact which remains undisputed is that the petitioner filed "nil returns" for three consecutive financial years, i.e., 1996-97, 1997-98 and 1998-99 on the ground that there was no transaction of purchase and sale during these years as stated in paragraphs 3 and 4 of the writ petition. The revisional authority in its order dated December 16, 2004 has held that the dealer had also no business during the year 1999-2000. Section 4 is the charging section, which deals with incidence of taxation. The liability to pay tax arises by virtue of the charging section alone. The liability to pay tax in case of a dealer comes into existence when the gross turnover exceeds the limit specified under section 4(7) of the OST Act. Sub-section (3) thereof says that the liability shall remain in force for three consecutive years although the gross turnover did not exceed the limit specified under sub-section (7). The liability to pay tax in case of a dealer comes into existence when the gross turnover exceeds the limit specified under section 4(7) of the OST Act. Sub-section (3) thereof says that the liability shall remain in force for three consecutive years although the gross turnover did not exceed the limit specified under sub-section (7). It further says that after the date of expiry of the period as may be prescribed, the liability of the dealer to pay tax under the Act shall stand ceased. In that event, the dealer shall apply along with the registration certificate to the authorities for cancellation of the certificate of registration granted to him. In case the dealer does not apply for cancellation of registration certificate, it is the duty of the STO concerned to cancel the same under section 9(6)(b) read with rule 16 of the OST Rules. As per rule 16, if the STO concerned, on information based on assessment records, finds that the gross turnover of any dealer during each of the three consecutive years has failed to exceed the specified limit, he can cancel the registration certificate. Even after a dealer ceased to be liable to pay tax, his liability again revives under sub-section (4) with effect from the month immediately following a period not exceeding twelve months during which his gross turnover again exceeds the limit prescribed in sub-section (7) of section 4. This court in State of Orissa v. Vijoy Laxmi Trading Co. [1973] 31 STC 438, held that the liability to pay tax under section 4 of the OST Act accrues as and when the condition laid down in section 4 itself is satisfied and without reference to the date of application for obtaining the certificate of registration or when the certificate of registration is granted. Section 9 says no dealer shall, while being liable under section 4 to pay tax under the OST Act, carry on business as a dealer unless he has been registered under this Act and possesses a registration certificate. Thus, a dealer is obliged under the statute to get registration certificate only when he is liable to pay the tax under section 4 of the OST Act. Section 9A(1) says, any dealer whose gross turnover during a period not exceeding 12 months exceeds Rs. Thus, a dealer is obliged under the statute to get registration certificate only when he is liable to pay the tax under section 4 of the OST Act. Section 9A(1) says, any dealer whose gross turnover during a period not exceeding 12 months exceeds Rs. 10,000, may, notwithstanding that he is not liable to pay tax under section 4 can apply for voluntary registration under the OST Act. Proviso to sub-section (2) of section 9A says that if the prescribed authority is satisfied that the applicant is liable to pay tax under section 4, he shall grant him the certificate of registration under section 9 notwithstanding the fact that the application has been made under sub-section (1) for voluntary registration. Thus, when the dealer becomes liable to pay tax under section 4, he ceases to be a dealer registered under section 9A of the OST Act and shall be treated as a dealer registered under section 9 of the OST Act. In the present case, initially, registration under section 9A of the OST Act was granted to the petitioner as he was not liable to pay tax under section 4 of the OST Act at the time of granting registration under section 9A of the OST Act. Subsequently, as it reveals from the assessment record maintained for the years 1994-95 and 1995-96, the petitioner returned its gross turnover at Rs. 2,99,612 and Rs. 2,20,250, respectively, and has been assessed on such turnover by the assessing officer. Thus, at least from the year 1994-95, the dealer must have been treated as a dealer registered under section 9 of the OST Act and in that event section 9(6)(b) is squarely applicable for cancellation of registration certificate of the petitioner. Apart from this, sub-section (6) of section 4 says that a dealer who is not liable to pay tax under the foregoing sub-sections shall nevertheless be liable to pay tax on sale or purchase, if such dealer is liable to pay tax under the CST Act or is registered as a dealer under the said Act. By virtue of sub-section (6) of section 4, a dealer is liable to pay tax under the OST Act, if he is liable to pay tax under the Central Sales Tax Act or registered as a dealer under the said Act. By virtue of sub-section (6) of section 4, a dealer is liable to pay tax under the OST Act, if he is liable to pay tax under the Central Sales Tax Act or registered as a dealer under the said Act. In the present case, the petitioner is registered under section 7(2) of the CST Act from December 31, 1992 and, subsequently, it was registered under section 7(1) of the CST Act on August 24, 1993 with effect from July 12, 1993. Thus by virtue of operation of sub-section (6) of section 4 the petitioner is liable to pay tax under section 4 of the OST Act and, accordingly, provision of section 9(6)(b) is applicable for cancellation of the registration certificate. Otherwise, also, registration certificate issued to a dealer under section 9A of the OST Act is liable to be cancelled by virtue of provision contained in section 9(6)(a) of the OST Act, if the business of the petitioner has been discontinued. In the present case, business of the petitioner was discontinued during four consecutive financial years, i.e., from 1996-97, 1997-98, 1998-99 and 1999-2000. The word "discontinued" has been, inter alia, defined in the Chambers Dictionary as "interrupted by intervening spaces". In Webster's Dictionary, it has been, inter alia, defined as "to terminate or abandon". Thus, even if the petitioner is treated as a dealer registered under section 9A of the OST Act during the relevant time, the said registration certificate is liable to be cancelled under section 9(6)(a), as its business was discontinued during four consecutive financial years. Similarly, since the petitioner - dealer has ceased to carry on business and also ceased to be liable to pay tax under the OST Act its registration certificate under the CST Act is also liable to be cancelled under section 7(4)(b) of the said Act. Therefore, the opposite parties have not committed any error in cancelling the registration certificates of the petitioner under the OST Act/CST Act with effect from April 1, 1999. The only ground of cancellation of registration certificates is that the petitioner had no business during the preceding three consecutive years. This being the reason for cancellation, it was always open for the petitioner to apply for fresh registration certificate whenever the condition laid down in section 4 was satisfied. The only ground of cancellation of registration certificates is that the petitioner had no business during the preceding three consecutive years. This being the reason for cancellation, it was always open for the petitioner to apply for fresh registration certificate whenever the condition laid down in section 4 was satisfied. There was also no bar for the petitioner even to obtain registration certificate voluntarily under section 9A of the OST Act. Similarly, there was also no bar for the petitioner to obtain registration certificate under the CST Act if it wanted to start inter-State business again. In the case at hand, learned counsel for the petitioner has failed to satisfy this court as to why such a convenient course has not been resorted to by the petitioner for obtaining a fresh registration certificate to carry on his business instead of challenging the orders of cancellation through revision and writ mostly on technical grounds. That apart, in the meantime, a reform has been brought to the sales tax system in various States of the country. Pursuant to such reform, the Orissa Value Added Tax Act, 2004 came into force with effect from April 1, 2005 in place of the OST Act in the State of Orissa. On being asked, the learned counsel for the petitioner also could not satisfy this court as to why the petitioner has not taken any step to obtain the registration certificate under the newly introduced VAT Act, 2004, to carry on its business. A prudent businessman is always in search of a way to solve his problem in the best convenient manner. His aim is to carry on business without involving himself in unnecessary and undesirable disputes for litigation sake. This is the normal human behaviour. In the present case, we do not find any reason as to why such a convenient course has not ever been adopted by the petitioner to obtain fresh registration certificate. The conduct of the petitioner appears to be very much suspicious. Mr. This is the normal human behaviour. In the present case, we do not find any reason as to why such a convenient course has not ever been adopted by the petitioner to obtain fresh registration certificate. The conduct of the petitioner appears to be very much suspicious. Mr. Dalei, learned counsel appearing for the Revenue, has also not brought any material to the notice of this court as to what steps the Revenue has taken to watch the business activities of the petitioner, if any, after cancellation of its registration certificate which is very much necessary in the present case as the petitioner without having business wants to possess a registration certificate under the OST and CST Acts. Another vital aspect of the case is that under section 9 and section 9A of the OST Act and section 7(1) and section 7(2) of the CST Act only a "dealer" is entitled to possess registration certificates under the said Acts. "Dealer", as defined in section 2(c) of the OST Act and section 2(b) of the CST Act, means a person who carries on business of purchasing and selling, supplying or distributing goods. In the present case, admittedly the petitioner is not carrying on any such business activities during consecutive four years. Hence, he is not entitled to possess registration certificate under the OST Act or CST Act. The STO has rightly cancelled his registration certificates under said Acts and the revisional authority is fully justified in upholding the said action of the STO. The revisional authority while rejecting the revision petition filed against the order cancelling the certificate of registration held as follows : "... in the present case the registration record of the petitioner clearly reveals that during the years 1996-97, 1997-98 and 1998-99 for three consecutive years the turnover is nil which is admitted by the petitioner by filing such nil returns. Therefore the action of the registering authority to cancel the certificate of registration is not unjust in the present case. Even perusal of the returns filed for 1999-2000 revealed that the dealer has no business during that year. Therefore, the cancellation of registration certificate even if given effect from April 1, 1999 has not affected the business of the dealer in any way. Even perusal of the returns filed for 1999-2000 revealed that the dealer has no business during that year. Therefore, the cancellation of registration certificate even if given effect from April 1, 1999 has not affected the business of the dealer in any way. After date of hearing on September 1, 2004 and before disposal of this revision petition, on November 3, 2004 and on December 14, 2004 the petitioner has filed another two petitions stating that in the meantime he has started the business transaction by investing Rs. 3.90 lakhs with IFCAL (Idcol Ferro Chrome & Alloys Limited) against EMD of a tender and Rs. 17.5 lakhs deposited to TISCO against the order for supply of materials like low ash metallurgical coke fines. If the petitioner wants to start business again nothing debars him to apply afresh for getting registered under the OST and CST Acts. By presenting all the facts before the concerned Sales Tax Officer and if such an application is made this cancellation order of registration certificate will, in no way, affect in getting him registered under both the Acts again. During the preceding years when he has no business there is no justification for claiming restoration of R.C. ..." Mr. Paikray, learned counsel for the petitioner, has also not been able to satisfy this court in what manner any prejudice was caused to the petitioner because of cancellation of registration certificate of the petitioner with effect from April 1, 1999, when it had no business during the preceding three consecutive financial years and also in the year 1999-2000. The honourable apex court in Rajendra Singh v. State of Madhya Pradesh AIR 1996 SC 2736 held that while examining complaints of violation of statutory rules and conditions, it must be remembered that violation of each and every provision does not furnish a ground for the court to interfere. The provision may be a directory one or a mandatory one. In the case of directory provision, substantial compliance would be enough. Unless it is established that violation of a directory provision has resulted in loss and/or prejudice to the party, no interference is warranted. Even in the case of violation of a mandatory provision, interference does not follow as a matter of course. In the case of directory provision, substantial compliance would be enough. Unless it is established that violation of a directory provision has resulted in loss and/or prejudice to the party, no interference is warranted. Even in the case of violation of a mandatory provision, interference does not follow as a matter of course. It is also well-settled principle of law that the courts are meant to determine the rule on living issues and not any academic question as it would be a futile exercise. The honourable Supreme Court in Loknath Padhan v. Birendra Kumar Sahu AIR 1974 SC 505 held that it is a well-settled practice recognised and followed in India that if an issue is purely academic in that its decision, which one way or the other would have no impact on the position of the parties, it would be a wastage of public time and indeed not proper exercise of authority for the court to engage itself in deciding such issue. In view of the above settled legal proposition, various issues raised by Mr. Paikray, learned counsel for the petitioner, have become academic and they do not need any adjudication. When the Department found that the petitioner is not carrying on any business for preceding consecutive three years and also in the very year of cancellation of registration certificates, it thought it proper to cancel its registration certificate, which is necessary for smooth tax administration. The person, who is not carrying on business, is totally unproductive for the Department and therefore there is no need for the Department to maintain records of such a person. The purpose and object is to weed out the dead wood from the list of registered dealers. Moreover, as the petitioner was not carrying on any business for a substantial period, it is not understood why it is interested to hold registration certificates for that period which would be nothing but like decorative pieces in the hands of the dealer - petitioner. In such fact-situation, we find no reason to entertain these writ petitions, which are accordingly dismissed. No costs. DR. B. S. CHAUHAN C.J. - I agree.