The words of Sir Maurice Gwyer In re the Central Provinces and Berar Act XIV of 1938 the learned JJ said–

“Subject always to the legislative competence of the taxing authority, a duty on home-produced goods will obviously be imposed at the stage which the authority find to be the most convenient and the most lucrative, wherever it may be; but that is a matter of the machinery of collection, and does not affect the essential nature of the tax”