Prospective tax amendment controls purchase tax only from its effective date, not prior stock held at year-end.

Liability to purchase tax depends on the law in force during the relevant assessment year, so a later amendment cannot retrospectively alter the tax point for prior turnover. The amendment introduced by Mysore Act 9 of 1970 operated only prospectively from 1 April 1970 and did not govern stock held during 1 April 1969 to 31 March 1970. Applying the principle on declared goods and single-point levy, groundnut and cotton stock in hand on 31 March 1970 had not yet become the last purchase inside the State for that year, so it was not exigible to purchase tax for the relevant assessment period.

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Issues: Whether the stock of groundnut and cotton held by the dealers on 31 March 1970 was liable to purchase tax under section 5(4) read with Schedule IV of the Mysore Sales Tax Act, 1957, as it stood before the amendment by Mysore Act 9 of 1970.

Analysis: Liability to tax had to be determined with reference to the law in force during the relevant assessment year. The amendment introduced by Mysore Act 9 of 1970 changing the point of levy operated only prospectively from 1 April 1970 and could not govern turnover for the period 1 April 1969 to 31 March 1970. Applying the principle stated in the earlier Supreme Court decision on declared goods and single-point levy, the stock in hand on the closing date had not yet acquired the character of the last purchase inside the State during the assessment year in question.

Conclusion: The stock held on 31 March 1970 was not exigible to purchase tax for the relevant assessment year, and the challenge to the Tribunal's view failed.

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