Repeal does not extinguish accrued tax liability where a saving provision preserves the pre-existing obligation.

Tax liability under the Cochin Sales Tax Act arose from the charging provision itself, while the assessment machinery merely quantified an already accrued obligation. The repeal of that Act by the later Travancore-Cochin sales tax legislation did not extinguish liabilities already incurred, because the general saving provision preserved them absent a contrary legislative intention. On that basis, the assessment, together with the appellate and revisional orders, remained valid and within jurisdiction, and the challenge based on repeal failed.

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Issues: Whether a sales tax assessment made after repeal of the earlier enactment was valid and enforceable under the repealed Act, and whether the assessment could be quashed for want of jurisdiction.

Analysis: The assessment was held to be under the Cochin Sales Tax Act, XV of 1121, and not under the later Travancore-Cochin Act. The Court treated section 4 of the Cochin Act as the charging provision and sections 9, 10 and 11 as machinery provisions for quantification of the pre-existing tax liability. On that basis, liability to tax arose from the charging section itself and was not created for the first time by the assessment order. The repeal of the Cochin Act by section 26 of the Travancore-Cochin General Sales Tax Act, XI of 1125, did not extinguish that accrued liability, because section 4 of the Travancore-Cochin Interpretation and General Clauses Act preserved liabilities already incurred unless a contrary intention appeared in the repealing legislation. No such contrary intention was found in the later Act.

Conclusion: The assessment and the appellate and revisional orders were valid and within jurisdiction, and the challenge to them failed.

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