Retrospective tax validation overrides prior court ruling and sustains enhanced assessments under amended sales tax law.

The Supreme Court of India held that the retrospective insertion of section 31 in the U.P. Sales Tax Act, 1948 validated the enhanced assessments and expressly overrode the earlier High Court judgment. Because the legislature had given the amendment retroactive effect and declared prior assessments and proceedings to be valid notwithstanding any contrary court order, the revising authority was bound to apply the amended law and could not be controlled by the earlier ruling. The court also rejected the objection that the amendment was inoperative for want of a separate machinery provision, finding no such difficulty on the facts and treating the retrospective validation as sufficient to restore the assessments in law.

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Issues: (i) Whether the retrospective insertion of section 31 in the U.P. Sales Tax Act, 1948, validated the enhanced tax assessments notwithstanding the earlier High Court judgment, and whether the revising authority remained bound to give effect to that amendment; (ii) whether the absence of a separate machinery provision rendered the amendment inoperative.

Issue (i): Whether the retrospective insertion of section 31 in the U.P. Sales Tax Act, 1948, validated the enhanced tax assessments notwithstanding the earlier High Court judgment, and whether the revising authority remained bound to give effect to that amendment.

Analysis: The amendment inserted section 31 with express retroactive effect and declared that assessments, orders, actions and proceedings under the earlier option-based regime would be deemed valid notwithstanding any judgment, decree or order of any court. Once the legislature had altered the law retrospectively, the revising authority was required to proceed under the law as amended, and the earlier High Court judgment could no longer control the final disposal of the assessment matter.

Conclusion: The amended provision operated retrospectively and displaced the earlier High Court ruling; the revising authority was justified in acting in accordance with section 31.

Issue (ii): Whether the absence of a separate machinery provision rendered the amendment inoperative.

Analysis: The contention that the amendment could not be implemented for want of machinery was rejected because no such difficulty arose on the facts of the case. The retrospective validation itself was sufficient to restore the assessments and make them good in law.

Conclusion: The amendment was not invalid for want of machinery.

Final Conclusion: The statutory amendment retrospectively validated the enhanced assessments and the impugned High Court order could not stand, so the revenue's position prevailed.

Ratio Decidendi: When the legislature retrospectively validates assessments and expressly overrides contrary judicial decisions, the assessment authority must apply the amended law and earlier judgments on the same matter cease to govern the final outcome.

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