Judgment

VENKATARAMA AIYAR, J. :These are appeals against the judgment of the High Court of Andhra Pradesh in petitions Nos. 1172 of 1956 and 56 of 1957 filed under Art. 226 of the Constitution questioning the validity of the Andhra Act XIV of 1955 insofar as it imposes a tax on the sale of Virginia tobacco, The appellants are firms doing business in the export of tobacco. The usual course of that business is stated to be that they first enter into contracts with their customers abroad for the sale of tobacco that thereafter they purchase the requisite quantities of goods locally and then export them to the foreign purchasers in performance of their contracts, Prior to October 1 1953, the area wherein the appellants carried on business formed part of the State of Madras, and on that date the State of Andhra was constituted, and the area in question fell within that State. The law relating to sales tax in force in that area is the Madras General Sales Tax Act, IX of 1939. Section 5 of this Act provides far exemption of tax on sales of goods specified therein and S. 6 confers on the State Government power to exempt the tax payable on the sale of any specified class of good or by any s