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Issues: Whether Article 286(3) of the Constitution invalidated the levy of sales tax under a pre-Constitution State sales tax enactment on sales of cocoanut oil after the commencement of the Essential Goods (Declaration and Regulation of Tax on Sale or Purchase) Act, 1952.
Analysis: Article 286(3) applied only to laws made by a State Legislature after Parliament had declared the relevant goods to be essential for the life of the community. The State sales tax law in question had been enacted before the Central Act of 1952 and therefore did not answer that description. The requirement of reservation for the President and his assent was thus inapplicable to the pre-existing State enactment.
Conclusion: Article 286(3) did not affect the validity or operation of the State sales tax law, and the tax liability continued.