The High Court summed up its conclusion as follows: 1.that the order dated January 18, 1947 of the Ruler of Gwalior State exempting the company from taxation had the effect of law and the agreement executed on April 7, 1947 cast an obligation on the Gwalior Government to exempt the ,company from taxation; 2.that by virtue of sections 3 and 4 of Madhya Bharat Act No. 1 of 1948, the company 's right to get the exemption received legislative recognition and the State of Madhya Bharat was bound to discharge the obligation undertaken by the Ruler of the Gwalior State which devolved on it; 3.that it was this obligation of the Madhya Bharat Government to fulfil the obligation undertaken by the Ruler of Gwalior State of granting exemption to the company that 902 devolved on the Government of India under article 295 (1) (b) and became a constitutional obligation of that Government; and 4.that on a true construction of the relevant provisions of the Income tax Act, section 13 of the Finance Act of 1950, and cl. 16 of the Taxation Concessions Order 1950, they did not repeal the specific exemption granted to the company by spe cial statutory provisions and that therefore the company 's claim for exemption from taxation was well founded.