Pre-existing sales tax law and superseding exemption order defeated milk society's claim to consumer-sale exemption.

A pre-existing sales tax statute remained operative because the Essential Goods Act, 1952 applied only against State laws made after its commencement, so the Madras General Sales Tax Act, 1939 continued to govern the levy. The earlier exemption for co-operative milk supply societies was limited in duration, and a later Government Order issued in supersession of it confined the relief and withdrew exemption for sales to actual consumers. The petitioner was therefore not entitled to exemption on consumer sales, and the tax assessment was confirmed.

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Issues: Whether co-operative milk supply societies were exempt from sales tax on sales of milk to consumers under the Essential Goods (Declaration and Regulation of Tax on Sale or Purchase) Act, 1952, and whether the earlier Government Order granting exemption continued despite the later Government Order superseding it.

Analysis: The Central Act operated only against State laws made after its commencement; a pre-existing sales tax law was not displaced by section 3 of the Act. The Madras General Sales Tax Act, 1939 therefore continued to govern the levy. The earlier Government Order granted exemption for a limited period, but the later Government Order expressly issued in supersession of the earlier notification confined the exemption and withdrew it in respect of sales to actual consumers. The earlier exemption could not survive the later superseding order.

Conclusion: The petitioner was not entitled to exemption from sales tax on sales to consumers, and the levy was upheld against the assessee.

Final Conclusion: The revision failed and the tax assessment stood confirmed.

Ratio Decidendi: A later statutory exemption or notification does not override a pre-existing tax law unless the legislature or the competent authority clearly displaces it, and a superseding notification abrogates the earlier exemption to the extent of inconsistency.

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