Transitional sales tax levy upheld where special enactment on timber stock was found non-retrospective and non-discriminatory.

The special sales tax enactment was upheld because it created a transitional taxation mechanism for timber stock arising from an amendment to the definition of manufacture, rather than an impermissibly retrospective levy. The Court found no unconstitutional classification or discrimination in the connected notification or the statutory scheme, and the challenge to validity therefore failed. As the enactment and notification remained valid, the petitioners' complaint regarding denial of set-off was not accepted in writ proceedings, leaving any statutory remedy under the Act to be pursued before the competent forum.

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Issues: Whether the special sales tax enactment and the connected notification were liable to be struck down as unconstitutional on the grounds of retrospectivity and discriminatory classification, and whether the petitioners were entitled to relief against denial of set-off.

Analysis: The levy was enacted to meet a specific contingency created by the amendment to the definition of manufacture under the principal sales tax law. The Court found that the enactment merely provided a special mechanism for taxation of timber held in stock during the relevant transitional period and for grant of set-off in specified circumstances. It was held that the legislation did not operate retrospectively in the impermissible sense, did not create any unconstitutional classification, and did not result in discrimination. The challenge to the validity of the enactment therefore failed. The Court also noted that, since the validity challenge was unsuccessful, the petitioners could pursue any statutory remedy available under the Act before the competent forum.

Conclusion: The special enactment and the notification were upheld, and the writ petition was rejected.

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