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Issues: Whether the Sales Tax Laws Validation Act, 1956 protected the assessment on sales said to be in the course of inter-State trade and commerce, so as to make the levy immune from challenge under Article 286(2) of the Constitution, and whether section 22 of the Madras General Sales Tax Act, 1939 altered that result.
Analysis: The validating statute was held to be wide enough to cover sales occurring during the specified period, and its effect was to remove the constitutional fetter under Article 286(2) rather than to require the State law to have expressly taxed inter-State sales in terms. The Court further held that the charging provision and the statutory definition of sale, together with the deeming explanation, brought the transactions within the Act. New section 22 did not cut down that liability, because its saving provision preserved tax liability under other provisions of the Act and the earlier repetition of Article 286(2) had become unnecessary once Parliament had lifted the ban.
Conclusion: The validating Act applied, the assessment remained lawful, and the challenge to taxability failed.