Uncompleted tax exemption notification was not law in force and could not survive State reorganisation.

A notice of intention to amend Schedule B under the Punjab General Sales Tax Act, 1948 did not itself have operative force; the exemption list changed only when a further notification was issued after the statutory notice period. Because the earlier notification had not matured into an amendment before State reorganisation, it was not a law in force within section 88 of the Punjab Reorganisation Act, 1966. The reorganisation provision protected only existing laws, and there was no deeming rule carrying forward the uncompleted notice as a valid notification of the Union Territory administration. Accordingly, the August 24, 1966 notification could not be relied on, and the January 4, 1968 amendment was invalid.

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Issues: Whether the notification issued by the erstwhile State Government giving notice of its intention to amend Schedule B could be treated as a law in force, and whether it could be availed of by the Union Territory Government after reorganisation to amend the sales tax exemption list.

Analysis: Under section 6 of the Punjab General Sales Tax Act, 1948, a notice of intention to amend Schedule B did not itself have operative force; the exemption schedule stood amended only on the issuance of a further notification after the statutory notice period. On the reorganisation of the State, the earlier notice had not matured into an amendment and therefore did not constitute a law in force. Section 88 of the Punjab Reorganisation Act, 1966 protected only laws in force immediately before the appointed day, and there was no deeming provision carrying forward the erstwhile Government's uncompleted notification as one issued by the new administration.

Conclusion: The notification of August 24, 1966 could not be relied upon by the Union Territory Government, and the amendment made on January 4, 1968 was invalid.

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