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The Gujarat High Court after referring to the history of the relevant amendments to the Gujarat Sales Tax Act and also to the C.S.T. Act observed in Pokardas [1982] 51 STC 88 that :

"The entry pertaining to cotton fabrics in the Schedule exempting goods from sales tax is supplemental legislative provision to the Central Sales Tax Act as well as the Excise Act and the Additional Duties of Excise Act. As a matter of fact, there is an integrated scheme evolved in connection with the goods of special importance in inter-State trade or commerce. The wholesome scheme of national integrity in the matter of commerce and trade is sought to be protected and preserved by providing against State intervention which is not always motivated by purely economic and fiscal consideration. Any attempt to divorce these well-connected provisions would have disastrous consequences, the immediate and ultimate implications of which, it is difficult to comprehend. Any attempt therefore to read the exemption provision contained in the Gujarat Act de hors the intimately connected provisions of the Excise Act and the Additional Duties of Excise Act may possibly result in rendering the exemption provisions wholly ineffective and unworkable. We are, therefore, of the opinion that since the referential legislation contained in entry 37 is supplemental to the Excise Act as well as the Additional Duties of Excise Act, the amendments made in the original incorporated provision must necessarily project and must be read as a part of the referential legislation contained in entry 37. The exception specified by the Supreme Court in Narasimhan's case , namely, where the subsequent Act and the previous Act are supplemental to each other, would squarely apply to the present case, and therefore, the incorporated provisions have to be read with all the amendments made in the borrowed provisions from time to time. In that view of the matter, therefore, we must read the enlarged definition as effected by the amending Act of 1980 in the referential legislation contained in entry 37 as if the law was all along the same according to the enlarged definition with effect from 1st March, 1955, and therefore, at all the relevant times of the assessment."

This in substance brings out the real purpose of giving retrospective effect to the amendment of tariff item No. 19 in the Excise Act.

8. The scope of the referential legislation was considered by the Supreme Court in (State of Madhya Pradesh v. M. V. Narasimhan). The point that arose for consideration was whether the meaning of the word "public servant" as defined under the Prevention of Corruption Act should be tagged on to the amended definition of the same word in the Indian Penal Code. The Supreme Court in reversal of the judgment of the Madhya Pradesh High Court on that point held that the amended definition of the Indian Penal Code would be applicable to the words "public servant" as defined under the Prevention of Corruption Act. The principle laid down by the Supreme Court in that case would be equally applicable to the cases on hand before us. Those principles are :