Retrospective sales tax amendment upheld: legislative power to tax prospectively also supports valid retrospective levy.

Retrospective sales tax amendment excluding pumping sets, threshers and discs from agricultural implements was upheld as constitutionally valid. The Court held that legislative competence to impose tax prospectively includes competence to impose the same levy retrospectively, and that goods earlier exempt do not remain immune merely because they become taxable by retrospective amendment. The length of the retrospective period, even if substantial, did not by itself make the amendment arbitrary or unreasonable. The challenge therefore failed, and the amendment was sustained.

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Issues: Whether the retrospective amendment to the sales tax entry excluding pumping sets, threshers and discs from agricultural implements was constitutionally invalid for imposing tax retrospectively over a long period.

Analysis: The challenge was confined to the retrospective operation of the amendment. The Court held that, once the legislature was competent to impose the tax prospectively, it was equally competent to give the amendment retrospective effect. The mere fact that goods earlier exempt may become taxable by reason of retrospective legislation does not, by itself, create constitutional infirmity. The length of the retrospective period also did not render the amendment arbitrary or unreasonable, since retrospective taxation over even a substantial period had been upheld in earlier binding decisions.

Conclusion: The retrospective amendment was valid and the challenge failed.

Ratio Decidendi: A legislature competent to levy a tax prospectively is equally competent to levy it retrospectively, and the length of the retrospective period alone does not invalidate the taxing amendment.

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