Official Gazette publication makes a tax notification effective, and an errata only corrects the existing rate change.

Publication of a tax notification in the Official Gazette gives it legal effect from the date of publication, so the revised jewellery tax rate applied from that date and the earlier concession could not continue merely because returns had been accepted at the old rate. An errata to the notification was treated as a correction of the existing instrument, not a fresh levy or prospective saving of the earlier concession; it reduced the rate from four per cent to three per cent. The earlier concessional rate was therefore held not to survive until the correction.

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Issues: (i) Whether G.O. Ms. No. 303 dated 15 April 1997 became effective on its publication in the Official Gazette so as to alter the rate of tax on jewellery from that date. (ii) Whether the errata dated 4 May 1998 merely corrected the earlier notification and reduced the rate of tax, or could be treated as operating prospectively to keep the earlier concessional rate alive.

Issue (i): Whether G.O. Ms. No. 303 dated 15 April 1997 became effective on its publication in the Official Gazette so as to alter the rate of tax on jewellery from that date.

Analysis: Publication in the Official Gazette gives legal effect to the notification from the date of publication and constitutes notice to all concerned. Once G.O. Ms. No. 303 was published on 23 April 1997, the earlier concession under G.O. Ms. No. 252 stood altered in accordance with the later notification. Any inadvertent acceptance of returns at the earlier rate could not override the statutory effect of the published notification.

Conclusion: The notification took effect from the date of its publication, and the tax position changed from that date.

Issue (ii): Whether the errata dated 4 May 1998 merely corrected the earlier notification and reduced the rate of tax, or could be treated as operating prospectively to keep the earlier concessional rate alive.

Analysis: The errata was not a fresh notification creating a new levy. It corrected the existing notification and showed that something already in existence was being amended. The correction operated to reduce the rate from four per cent to three per cent. The contention that the errata implied non-existence of the earlier notification was rejected, as the legal effect of the earlier notification remained until altered by the correction.

Conclusion: The errata was only a correction and reduced the rate of tax; it did not support continuation of the earlier two per cent rate.

Final Conclusion: The High Court's view that the earlier concessional rate continued for the disputed period was incorrect, and the published notification was held to govern the tax rate until modified by the errata.

Ratio Decidendi: A notification published in the Official Gazette takes effect from the date of publication, and an errata merely corrects the existing notification rather than negating its prior existence or operation.

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