STATE OF PUNJAB & ORS. vs SUKH DEB SARUP GUPTA

The Supreme Court upheld the High Court's decision that the respondent's medicinal preparations were exempt from sales tax under Entry 37 of the East Punjab General Sales Tax Act, 1948, despite the repeal of the Punjab Excise Act, 1914, by the Central Medicinal and Toilet Preparations (Excise Duties) Act. The Court interpreted Section 8 of the General Clauses Act, 1897, to mean that references to the Punjab Excise Act should include the corresponding Central Act. The ruling clarified that the term 'former enactment' in Section 8 encompasses both State and Central laws, affirming the applicability of the exemption even after the repeal of the State Act.