ISSUE:
Whether any attempt to impose a tax on the first sales of products made or produced in India in Madras would be outside the scope of the Respondent's legislative authority and ultra vires?
RULE:
The Madras General Sales Tax Act, 1939 levies a tax on the sale of products, which is its “Pith and Substance.” It can only be accurately described as a “tax on the selling of products”.