This article is written by Harshita Agrawal. The article includes a detailed examination of the landmark judgement of South India Corporation (P) Ltd. vs. Board of Revenue, (1964) highlighting the significance of the assessment year and the resulting tax enhancement. It delves into the scope outlined in this case within the Indian Constitution along with the implications for the savings of taxes, duties, cesses, and fees, as well as its broader applications. The judgement of the case is analysed using examples from several precedent cases to support the decision.

This article has been published by Shashwat Kaushik.

Introduction 

The case of South India Corporation (P) Ltd vs. Board of Revenue, (1964), highlights the constitutionality of tax assessments related to “work contracts”. The validity of agreements between the President of India and the Rajpramukh of the State of Travancore-Cochin was also reviewed by the honourable Supreme Court and the court held that the expression “subject to” expresses the idea that one provision must yield to another provision or the subordinated provision. An agreement was made on 25th February 1950 between the President of India and the Rajpramukh of the State of Travancore-Cochin which limited the authority of the State to levy taxes on “work contracts” for a period of ten years as specified in the agreement. The four petitions were filed by the appellant in Kerala High Court under Articles 226 and 227 of the Constitution of India and were rejected by the court. The court dismissed the petition and ordered costs. Since the argument of the petitioners was rejected by the court they opted to file an appeal. The judgement of the Supreme Court aimed to nullify the previous order of the High Court as the case discussed a pre-constitutional law along with several previous precedents and constitutional amendments and ruled that the state could not impose such taxes during the specified period. ..

The article discusses the facts of the case, its historical background, the issues involved, and the judgement and analysis of the case.

Details of the case

Name of the case: South India Corporation (P) Ltd vs. Board of Revenue

Name of the court: Supreme Court of India

Date of judgement: 13th August, 1963

Citation: 1964 AIR 207, 1964 SCR (4) 280

Bench: Justice S. K. Das, Justice Subba Roy, Justice Raghubar Dayal, Justice N. Rajagopala Ayyangar, Justice Justice R. Mudholkar

Authored by: Justice Subba Roy

Name of the parties:

• Petitioner: South India Corporation (P) Ltd.
• Respondent: The Secretary, Board of Revenue

Background of the case 

The petition of the case of South India Corporation (P) Ltd. vs. Board of Revenue, 1964 was filed under Article 226 of the Indian Constitution. The four linked appeals arose out of a ruling by the Kerala High Court where all the petitions were dismissed seeking to declare that the provisions of the General Sales Tax Act, 1125 (Act XI of 1126), stating that tax was imposed on “work contracts” and should not be enforceable in any part of Kerala State with effect from 26th January 1960. A writ of certiorari was issued along with other appropriate writs to annul orders for the tax imposed on sales on “work contracts” for the assessment years 1960-61 and 1961-62 was also requested by the appellant. A revised petition was filed by the company before the first respondent and was dismissed. The sales tax assessment was issued by the second respondent against the company for the assessment years 1956-57, 1957-58 and 1958-59 in respect of “work contracts”. The initial argument before the High Court of Kerala which was put forward on behalf of the appellant was that the pertinent Sales Tax Acts enforce the collection of sales tax on “work contracts”. It was considered as unconstitutional and therefore void after the enactment of the Indian Constitution. The petition was dismissed and rejected, with costs imposed, leading to file an appeal.

Facts of South India Corp. (P) Ltd. vs. Board of Revenue (1964) 

The appellant of the case is an incorporated private limited company under the Companies Act, 2013. The headquarters is located in Mattancherry. The company engages in a variety of sectors including iron, hardware, electrical goods, timber, coir and engineering contracts. The company also served as an engineering contractor for state and central government departments as well as private entities. On 17th March 1959, the Sales Tax Officer, Special Circle, Ernakulam, levied sales tax on the company under the Travancore Cochin General Sales Tax Act, 1125 M.E for the assessment year 1952-53 in respect of “work contracts”. The assessment for the year 1952-53 was conducted solely under the Travancore-Cochin General Sales Tax Act (11 of 1125 M.E). Hence, the subsequently increased tax did not impact the assessment of that year. However, assessments for the years 1956-57, 1957-58 and 1958-59 were made under the Travancore-Cochin General Sales Tax (Amendment) Act, 1957. Therefore, the provision increasing the rate under this Act would impact those assessments. The enhancements made under the Kerala Act, 1957 would only apply to the assessment year 1957-58 and would not apply to the assessment year 1956-57.  

Historical background of the Sales Tax legislation in Kerala

Initially, Travancore and Cochin were two separate sovereign states with complete taxation authority. Cochin implemented the Cochin General Sales Tax Act 15 of 1121 M.E, while Travancore enforced the Travancore General Sales Tax Act 18 of 1124 M.E, both Acts imposing taxes on “work contracts”. Following the merger of these states, the United States of Travancore-Cochin was established with a unified legislature. The legislature enacted the Travancore-Cochin General Sales Tax Act 11 of 1125 M.E hereafter referred to as ‘the Act’. The legislature imposed a Sales Tax on “work contracts” with full taxation authority. 

On 17th January 1950, the Act was officially published in the Gazette. Provided thereof in Section 1(3) that it would become effective on a date specified by the government through the notification which was issued on 30th May 1950. As per Section 24 of the above specified Act, the rules were framed describing procedures and for ascertaining sales amounts related to “work contracts”. According to rule 4(3) sub-rule (1), the value of goods sold by a dealer in connection with “work contracts” were deemed to be the payment made for the completion of the contract, less a certain percentage fixed by the Board of Revenue for different regions. This percentage represents the usual proportion of labour costs to material costs in those areas with a specified maximum percentage. 

However, the Revenue Board did not specify the deduction percentage for executing a work contract. Since the stated fact was accepted in the High Court, evidence from the Travancore-Cochin Gazette was presented before the court confirming the establishment of such a percentage. 

Issues raised 

• Can a valid agreement be made under Article 278 of the Constitution regarding taxes levied by the State and those levied by the Indian Government until the Parliament enacts a suitable legislation?
• Was there an agreement wherein the State relinquished its authority to levy the aforementioned tax as part of an arrangement made with the union?
• Whether Article 372 of the Constitution is subject to Article 277 thereof?
• Whether Article 372 of the Constitution is subject to Article 278 thereof?

Arguments of the parties

Petitioners

The primary argument of the petitioner is that Article 227 of the Constitution of India can only preserve the taxes lawfully enforced by a state prior to the commencement of the Constitution and as the Act was enacted after the Constitution, the imposition of tax under it does not meet the criteria set by the Article. 

If it was assumed that Article 227 upheld the taxation imposed by the Act, the petitioner further contended that an agreement was made on 25th February 1950 between the President of India and the Rajpramukh of the State of Travancore-Cochin regarding federal financial integration in the State. 

As per this agreement, the union committed to compensate the State for the revenue shortfall resulting from the constitutional transfer of taxation powers concerning specific items to the union List and after that, the State lost its authority to levy tax on the transferred subjects. 

The petitioner also argued that Article 372 is subservient to other constitutional provisions and that a power granting a State authority to impose taxes on a federal subject contradicts the federal framework of the Constitution and is deemed invalid.

Respondent 

The respondent in his arguments suggested that the Travancore-Cochin General Sales Tax Act of 1125 M.E remained operative post-Constitution under the explicit provisions of Article 372 and continued until the said law was modified, repealed or amended by the appropriate authority. Therefore, any agreement between the union and the State mentioned would not diminish the State’s authority to levy taxes under the said law. 

The respondent argued that Article 278(2) gave permission to the union and a Part B state to enter into an agreement solely concerning tax levied by the government of India within that State and when a State incurred revenue loss due to its loss of power to levy and collect the tax under the Constitution. 

In the case of South India Corporation (P) Ltd. vs. Board of Revenue, (1964), it was established that the State retained the authority to levy taxes on “work contracts” until the Parliament enacted appropriate legislation as permitted by Article 277. However, it did not suffer any revenue loss concerning this tax rendering any agreement between the state government and the union invalid. 

Article 278 came into play only when the government of India acquired the authority to levy a special tax saved by Article 277 through parliamentary action as an agreement to compensate for the loss of revenue invalidated when there is no such loss.  

Laws discussed in South India Corp. (P) Ltd. vs. Board of Revenue (1964)

Section 2(68) of the Companies Act, 2013

As per Section 2(68) of the Companies Act, 2013, a private company is the one with minimum prescribed paid-up share capital and which by its articles:

• Restricts the right to transfer its shares,
• Except in the case of One Person Company, limits the number of members to two hundred.

Provided that where two or more persons jointly hold shares in a company, they shall be treated as a single member for this provision.

Provided further that:

Persons who are in the employment of the company, and

Persons who, having been previously employed by the company, were members of the company while employed and have remained members after the employment ceased, shall not be counted among the members, and

A private company prohibits any invitation to the public to subscribe to its securities.

This provision deals with a private company and South India Corporation (P) Ltd. would be classified under the definition of private company to make it relevant in the context of legal principles.

Article 12 of the Indian Constitution

With a few exceptions, all the fundamental rights are applicable against the State. According to  Article 12, unless the context requires otherwise, “the State” encompasses-

• The Government and Parliament of India,
• The Government and the Legislature of each State, and
• All local or other authorities,
• Within the territory of India, or
• Under the control of the Government of India.

The term ‘local authorities’ pertains to bodies such as Municipalities, District Boards, and Panchayats. The Supreme Court has ruled that ‘other authorities’ encompasses all authorities created by the Constitution or statute to which powers are conferred by law without necessitating engagement in governmental functions.

In Ajay Hasia vs. Khalid Mujib, (1981), the Supreme Court has enunciated the following test for determining whether an entity is an instrumentality or agency of the State:

• The extent to which the State provides financial assistance particularly if it covers a significant portion of the corporation’s expenses may suggest the corporation’s association with the government.
• If the corporation holds a monopoly status granted or safeguarded by the State, indicating a government connection.
• The presence of extensive State control can suggest that the corporation functions as an agency or instrumentality of the government.
• If the activities of the corporation are of significant public importance and closely aligned with government functions, it strengthens the case for classifying it as a government agency or instrumentality.
• If a department of government is transferred to a corporation, it would be a strong factor supporting the inference that the corporation acts as a government agency or instrumentality.
• When the entire share capital of the corporation is owned by the government. 

The Article in the case clarified the authority of the Board of Revenue being a State’s authority and subjected to the enforcement of the constitutional provisions.

Article 226 of the Indian Constitution

Under the Constitution, by virtue of Article 226, every High Court has the power to issue directions or orders or writs including writs in the nature of Habeas Corpus, Mandamus, Prohibition, Quo Warranto and Certiorari. The jurisdiction to issue writs is conferred upon the High Courts under Article 226 and the Supreme Court under Article 32 of the Constitution of India.

The writ of certiorari transfers proceedings from a lower body to the High Court in order to annul a decision that exceeds its jurisdiction. If a lower court has accepted a case beyond its jurisdiction and authority then the High Court under Article 226 or Supreme Court under Article 32 can issue a writ or order known as Prohibition by which the lower court will be prohibited from adjudging the case but if it has already passed a judgement then they shall issue certiorari order by which judgement of the lower court will be quashed.

In Veerappa Pillai vs. Raman and Raman Limited, (1952), it was held that the writs mentioned in Article 226 were intended to allow the High Court to intervene when subordinate bodies or officers act beyond their jurisdiction, violate natural justice, fail to exercise their jurisdiction, or commit clear errors that lead to injustice. No matter how extensive its jurisdiction, the High Court is not authorised to act as a court of appeal or to evaluate the correctness of disputed decisions and determine the appropriate position or order to be issued.

In the above-mentioned case, the petitioner filed the petition under Article 226 to relief from the actions of the respondent mentioning that the imposition of certain taxes were unconstitutional. 

Article 227 of the Indian Constitution

Article 227 of the Constitution of India concerns the authority of High Courts to supervise all courts. In pursuance of this Article, every High Court possesses supervisory jurisdiction over all courts and tribunals across the territories within its jurisdiction. Without prejudicing the general scope of the above position, the High Court may:

• Request the return of documents from these courts.
• Make and issue general rules and establish forms to govern the practice and procedures of these courts.
• Determine the formats for maintaining books, entries and accounts by the officers of these courts.
• The High Court has the authority to establish fees for the sheriff and all clerks and officers of these courts, as well as for attorneys, advocates and pleaders practising therein.

Provided that any rules made, forms prescribed or fee schedules set under clauses (2) or (3) must align with the existing laws and require the prior approval of the governor.

The Article does not confer upon the High Court any authority of superintendence over any court or tribunal established by or under laws concerning the Armed Forces.

The Supreme Court referred to various precedents that delineated the scope, authority and distinctions between Articles 226 and 227. After reviewing its prior judgement in Surya Devi Rai vs. Ram Chander Rai, (2003), the Hon’ble Supreme Court clarified that Article 226 empowers the High Court to issue directions, orders and writs to any person, government or authority, while Article 227 grants the High Court supervisory authority over all courts and tribunals within its jurisdiction. The actions under Article 226 fall within the High Court’s original jurisdiction and the procedures under Article 227 are purely supervisory in nature. The writ of certiorari falls under the High Court’s original jurisdiction (Article 226) and supervisory jurisdiction (Article 227) is not original jurisdiction and is more akin to appellate revision. The authority under Article 226 can be exercised by a plea from the aggrieved party or on their behalf and the supervisory jurisdiction can also be exercised suo moto under Article 227.

The provision for this case ensured High Courts supervise lower courts or tribunals dealing with tax disputes, ensuring they operate within their jurisdiction and adhere to due process.

Article 277 of the Indian Constitution

Article 277 of the Constitution of India deals with savings. It stipulates that any taxes, duties, cesses or fees lawfully imposed by the government of any state or by the municipality or other local authority before the commencement of the Constitution shall persist and continue to be utilised for the same purposes until the Parliament enacts legislation to the contrary.

In the landmark judgement of Town Municipal Committee vs Ramchandra Vasudeo Chimote, (1964), the actions of the Municipality of Amravati were held illegal by the Supreme Court as it was considered incompetent to make alterations in the pre-constitutional taxes, duties or fees. The municipality previously imposed a terminal tax on goods, with the exception of gold and silver as per a specific pre-constitutional law. After the Constitution came into force, the power lay under List 1 of the Seventh Schedule. However, the municipality amended the notification including gold and silver within the scope of terminal tax following the commencement of the Constitution of India.

The relevancy of this Article for this case was to determine whether the taxes imposed pre-constitution could still be validly imposed by the state government.

Article 372 of the Indian Constitution

Article 372 in the Constitution of India addresses the continuity and adaptations of existing laws. Despite the repeal of the enactments mentioned in Article 395 subject to the other provisions of this Constitution all laws in force in the territory of India immediately before its commencement shall remain effective until they are altered, repealed or amended by a competent legislature or authority.

To align the existing laws in accordance with the provisions of this Constitution, the President may issue orders for necessary adaptations and modifications, including repeal or amendment. Provided that the law shall take effect from the date specified in the order and shall not be questioned in any court of law.

However, clause (2) does not authorise the President to make any adaptations or modifications of any law after three years from the commencement of this Constitution. It also prohibits any competent legislature or other competent authority from repealing or amending any law adopted or modified by the President under this clause.

Since Article 372 deals with the continuance of existing laws until repealed by a competent authority, the case here discussed whether pre-constitutional tax laws continued to be valid post-constitution. 

Judgement in South India Corp. (P) Ltd. vs. Board of Revenue (1964)

It was admitted by the counsel of the respondent that the tax assessments for 1956-57, 1957-58 and 1958-59 were invalid under the Travancore-Cochin General Sales Tax (Amendment) Act, 1957 and the Kerala Surcharge on Taxes Act (Act 11 of 1957). However, he requested permission for the State to reassess the appellant for those years under the Act. The Supreme Court after hearing the appeals and arguments held that the decision of assessment of the orders should not be enforceable and no costs to be awarded here or in the High Court. However, a single set of hearing fees was allowed and the appeals were permitted.

Issue wise judgement

Can a valid agreement be made under Article 278 of the Constitution regarding taxes levied by the State and those levied by the Indian government until the Parliament enacts a suitable legislation?

The court held that the conjunction of Articles 277 and 278 read with the agreement confers the authority to impose and collect the duty on the union of India. Therefore, the court concluded that following the enactment of the Constitution, the excise duty in question could only be imposed by the government of India. Despite the temporary reservation in support of the State of Rajasthan until Parliament enacted an appropriate law, the court ruled that an agreement under the Act could still be made concerning such a levy. 

The court also highlighted the sole difference between the case of State of Rajasthan vs. G. Chawla, (1959) and the current one is that when the agreement between the union and the State was made, the Parliament had not yet passed the necessary legislation to deprive the State of its power to levy taxes on “work contracts”. However, this difference does not alter the principle as the previous decision pertained to the validity of the agreement concerning arrears leviable by the State before the enactment of the relevant law. The provision in Article 278 effectively overrides the authority of the state government to continue levying taxes under Article 277.

Was there an agreement wherein the State relinquished its authority to levy the aforementioned tax as a part of an arrangement made with the union?

In accordance with the Constitution of India, the agreement between the President of India and the Rajpramukh of the State of Travancore-Cochin unless specified otherwise by the context of the Committee’s report and this agreement remained in effect for a period of ten years from the commencement of the Constitution. It incorporated recommendations of the Indian States Finance Enquiry Committee with certain alterations. Under this agreement, the Union of India consented to provide compensation to the State for the incurred loss due to federal financial integration as described therein.

It was not a partial agreement limited to specific items, but rather aimed to offset the entirety of the revenue deficit experienced by the State due to the loss of certain revenue sources to the union or otherwise. Key recommendations of the Indian States Finance Enquiry Committee incorporated in the agreement highlight the thoroughness of the agreement.

The committee examined and reported on various aspects including the gradual integration of federal finance in Indian states and the manner in which it should be carried out, specifying that it entailed transferring all “federal” revenues to the centre but also the undertaking of all expenses in states associated with “federal” departments and services.

Chapter 11 of Part II detailed the transfer of “federal” revenues and expenditures in States to the centre along with the admiration of the relevant departments. It also assumed all the outstanding liabilities, claims and assets associated with these departments by the centre.

Whether Article 372 of the Constitution is subject to Article 277 thereof?

Article 372 is a broad provision while Article 277 is specific in nature. As per legal principles, a special provision should be given effect within its defined scope, leaving the general principles to apply to cases where the special provision could not be applicable. The preceding conversation made it clear that the subject of finance is treated separately by the Constitution. Article 277 safeguards the existing taxes, duties, cesses or fees levied by States provided the mentioned conditions are met. On the other hand, Article 372 preserves all the valid pre-constitutional laws. Article 372 cannot be interpreted to broaden the scope of tax-saving issues. To state it differently, Article 372 must be understood within the framework of Article 277.

Whether Article 372 of the Constitution is subject to Article 278 thereof?

Article 278 functions independently in spite of the continued force of pre-constitution taxation laws under Article 372. A pact between the union and the state government under Article 278 can override state laws in Part B states. During the agreement period, in view of Article 277 excluding Article 372 operation or as an agreement overriding Article 278 the result remained consistent and the State lost their authority to impose taxes on “work contracts”. 

Rationale behind this judgement

The court concluded from the agreement read with the report which indicates that the provisions were made to compensate the State for the loss on account of the federal financial integration that seemed to cover the State’s revenue loss due to the transfer of specific revenue sources to the union under the Constitution. It would be unreasonable to interpret the agreement to exclude certain temporarily authorised taxes. The savings clauses were contingent upon an agreement and the effective adjustments were made through the agreement to offset any losses which the State would have incurred, rendering the savings clause unnecessary thereafter. 

The court also stated that the question of whether the State’s authority was revived after the expiry of ten years from the commencement of the Constitution is not relevant in this case as all contested assessments fall within that time frame. The argument that Article 278 was omitted by the Constitution (Seventh Amendment) Act, 1956 terminated the agreement and subsequently, the State regained the authority to impose the tax. The validity of an agreement depends on the presence of authority at the time of its formation and the duration is specified by its terms or the conditions of the granted authority. Article 278 empowered the union and the Part B states to enter into an agreement lasting up to ten years from the commencement of the Constitution. The agreement in consideration fell within the purview and the Seventh Amendment being prospective did not invalidate it. Therefore, the court concluded that the contested assessment orders were not validly issued by the sales tax authorities as they exceeded the authority granted under Article 277 of the Indian Constitution.

The Supreme Court in its view stated after the decision made by the United States of America in the case of Vilas vs. City of Manila, (1911), that they were not focusing solely on the explicit provisions of Article 372 of the Constitution rather than delving into the general principles outlined by American law. Apart from this, it might be also inappropriate to draw parallels between the legal outcomes of a State’s cessation under American law and the interpretation of Article 372 in the Indian Constitution. The court therefore confined their attention to the specific provisions of the Constitution.

Analysis of South India Corp. (P) Ltd. vs. Board of Revenue (1964) 

The previous laws of Travancore and Cochin were revoked with effect from 30th May 1950 until sales tax on “work contracts” was previously imposed under the respective Acts and rules framed thereunder leading to the imposition of tax under the new Act and its accompanying rules. The State Reorganisation Act, 1956 came into force on 1st November 1956 and the new state of Kerala was formed. The area previously covered by the Travancore-Cochin State (excluding a small part) and the Malabar District of the Madras State comprises this new state. Subsequently, the Kerala Legislature enacted the Travancore-Cochin General Sales Tax (Amendment) Act, 1957 which modified the Act to encompass the entire territory of Kerala. The said Act came into force on 1st October 1957 and contained the provisions of the earlier Act. The State of Kerala denied any increment in tax on electrical goods or that any tax was levied on cement involved in “work contracts”. The sales tax imposed under the Act was further enhanced by the Kerala Surcharge on Taxes Act, 1957 and again by the Kerala Surcharge on Taxes Act, 1960.

According to Article 372 of the Indian Constitution, the provisions of the Travancore-Cochin Act of 1125 would not persist as they were incompatible with the constitutional framework and the provisions of Part XII.

The respondent cannot rely upon Article 227 of the Constitution of India as it is applicable only if:

• The specific tax was lawfully imposed by the state government immediately before the commencement of the Constitution and is explicitly listed in the Union List. 
• The pre-requisites for a direct alignment between the tax enforced by the State before the Constitution and the tax upheld thereafter concerning the rate, jurisdiction, state and purpose are not fulfilled. 

The applicability of Article 277 could not be relied upon by the appellant as an agreement between the Rajpramukh of Travancore and the union government as per Article 278 of the Indian Constitution, intervened.

The Act in question, with its taxation on “work contracts” violates Article 14 of the Constitution of India by unevenly applying its provisions, resulting in this consistency in discriminatory treatment particularly by excluding those outside the Travancore-Cochin States.

The Board of Revenue failed to specify the deduction percentage under Rule 4(3) of the Act, which made the assessment illegal for the assessment year 1952-53.

The phrase “subject to the other provisions of the Constitution” indicates that if there is an irreconcilable conflict between pre-existing laws and constitutional provisions, the latter shall prevail within that scope. A constitutional article may conflict with a pre-constitutional law either entirely or partially. The cumulative effect of a series of articles may render pre-existing laws inappropriate in certain contexts. Any inconsistency must be spelt out from the explicit provisions of the Constitution and not from the presumed political philosophy underlying the Constitution.

Conclusion 

The above-mentioned reasonings and factors concluded the importance of the case in respect of the Constitution and the matters related therein. The article aimed to maintain the continuity of pre-existing laws after the Constitution came into effect until repealed, altered or amended by a competent authority. Without this provision, legal confusion would arise. The Constitution assumes that state laws may or may not fall within the legislative competence of the appropriate authority. If pre-commencement laws were required to align strictly with the legislative framework of the Constitution of India, the article would become ineffective and purposeless. 

Frequently Asked Questions (FAQs)

What do you mean by cess on income tax?

A cess is a form of income tax and additional levy imposed by the central government to raise funds for a specific purpose. Cesses are utilised only when there is a requirement to address particular public welfare expenditures.

What do you mean by a surcharge in Income Tax?

A surcharge on income tax is an additional tax imposed by the government on taxpayers earning a higher income beyond a certain limit set by the government. It is calculated as a percentage of a taxpayer’s taxable income.

What is a “work contract”?

A contract of service may involve the supply of goods in its execution of the said contract, representing a composite supply of both services and goods with the service component being predominant in the agreement between the parties.

A work contract, incorporating elements of both the provision of services and the sale of goods, was consequently taxable under both laws.

What is existing law and law in force?

Existing law refers to the law currently in operation and law in force encompasses not only law actually in force but also law potentially in force to be extended through notification and by other means.

What is a Part B state?

Part B states consisted of nine erstwhile princely states with legislatures. Rajpramukh was appointed by the President of India and served as the ruler of a constituent state with an elected legislature. Part B states included Patiala and East Punjab States Union, Hyderabad, Jammu and Kashmir, Travancore-Cochin, Madhya Bharat, Mysore, Rajasthan and Saurashtra.

References

• https://blog.ipleaders.in/all-you-need-to-know-about-article-226-of-the-indian-constitution/
• https://icmai.in/TaxationPortal/upload/IDT/Article_GST/14.pdf