Territorial limits of fiscal law prevent a saved sales tax concession from extending after State reorganisation.

A fiscal statute operates territorially, so a sales tax concession attached to a licensed dealer in hides and skins could not survive beyond the territorial field for which it was originally granted after State reorganisation. Section 53 of the Andhra State Act, 1953 preserved existing laws in the new State, but it did not deem the former Madras territory to remain part of Madras for applying the Madras General Sales Tax Act, 1939. The saving provision therefore did not extend the single-point concession to transactions outside the former territorial operation of the Madras law.

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Issues: Whether a licensed dealer in hides and skins continued to enjoy the single-point sales tax concession after the formation of the State of Andhra, by reason of Section 53 of the Andhra State Act, 1953.

Analysis: Under the Madras General Sales Tax Act, 1939 and the relevant Rules, the concession in respect of hides and skins operated within the territorial limits of the State in which the law applied. Section 53 of the Andhra State Act, 1953 preserved the existing laws in the territories included in the new State, but did not deem those territories to remain part of Madras for the operation of the Madras sales tax law. The formation of the new State, coupled with the territorial limits of the taxing statute, meant that the licence could not confer the same concession beyond the boundaries of the State in which it operated. The continued force of the Madras enactment in the newly formed State did not authorise a claim that the Madras concession survived unchanged after reorganisation of the State.

Conclusion: The licensed dealer was not entitled to the single-point tax concession for transactions outside the former territorial operation of the Madras law after the formation of Andhra; the contention failed.

Final Conclusion: The revision was dismissed, and the tax authority's view that the concession did not extend beyond the territorial limits affected by State reorganisation was sustained.

Ratio Decidendi: A fiscal statute operates territorially, and a saving provision preserving existing laws on State reorganisation does not extend a tax concession beyond the territorial field for which it was originally granted.

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