J.C.SHAH, J.

(1) BHOPAL Sugar Industries Ltd. hereinafter called the Company-was incorporated under the Companies Act of the former Indian State of Bhopal. In 1953 the State of Bhopal which was then a Part C State under the Constitution of India enacted `The Bhopal State Agricultural Income-tax Act, IX of 1953` providing for imposition and levy of tax on agricultural income. The Act was applied to the territory of the entire State of Bhopal and was brought into force on 15/07/1953.

(2) BY the States Reorganisation Act, 1956 (No. 67 of 1956), territory of the Part C State of Bhopal was incorporated with effect from 1/11/1956, into the newly formed State of Madhya Pradesh. Section 119 of the States Reorganisation Act, 1956, enacted that by the constitution of the reorganized State, no change in the laws in force which immediately before 1/11/1956, extended or applied to any constituent regions, was effected, and territorial references in the laws to an existing State shall, until otherwise provided by a competent Legislature or other competent authority be construed as meaning, the territories within that State immediately before 1/11/1956. By the Madhya Pradesh Adaptat