THE PUNJAB STATE, CHANDIGARH vs SANSARI MAL PURAN CHAND

The Supreme Court held that the amended Section 5 of the East Punjab General Sales Tax Act, 1948, was valid for imposing sales tax on non-essential goods but could not impose tax on essential goods until the amendment of Article 286(3) of the Constitution on September 11, 1956. The Court ruled that the notification regarding tax-free goods was ultra vires as it did not receive Presidential assent, thus entitling the respondents to exemption for sales of edible oils prior to the amendment. The Court affirmed that after the amendment, the imposition of tax on essential goods was permissible.