This case involved the interpretation of the Madras Sales Tax Act, 1939, before its amendment in 1947. The appellant, Poppatlal Shah, a partner in Indo-Malayan Trading Company (based in Madras), ... challenged the imposition of sales tax on transactions where the property in the goods passed outside the Madras province. The primary legal issue was whether the Madras Sales Tax Act could validly impose tax on sales where the goods' property passed to buyers outside the province.