JUDGMENT

PATHAK, CJI.:— The appellants in these two appeals are manufacturers of Ayurvedic drugs and medicines, including Arishtams and Asavas. Arishtams and Asavas contain alcohol, and it is said that the presence of alcohol is essential for the effective and easy absorption of the medicine by the human system and also because it acts as a preservative. All the Ayurvedic preparations as well as Allopathic, Siddha and Unani medicines were originally subject to a multipoint levy of 31/2% under the Tamil Nadu General Sales Tax Act, 1959. By a notification dated 4 March, 1974, the State of Tamil Nadu included a large number of items in the First Schedule to the aforesaid Act in order to make them subject to a single-point -levy. While all other patent or proprietary medicinal preparations belonging to the different systems of medicines were taxed at the rate of 7% only, arishtams prepared under the Ayurvedic system were made subject to a levy of 30%. It seems that representations were made to the State Government against the high rate of tax on Arishtams, and therefore a separate entry was introduced by Tamil Nadu Act No. 23 of 1974 in the First Schedule as item 135 dealing specifical