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Issues: Whether the enhanced fee prescribed by the amended Rule 29(1)(c) of the Tamil Nadu General Sales Tax Rules, 1959 applied to appeals arising from assessments initiated before the amendment.
Analysis: The right of appeal is a substantive and vested right that accrues when proceedings are first initiated, and it is governed by the law then in force unless a later enactment clearly provides otherwise. An amendment that does not take away the appeal itself but imposes a higher appeal fee still burdens that vested appellate right because it introduces a more onerous condition. In the absence of express words or necessary intendment making the enhancement retrospective, the amended fee provision cannot govern appeals arising from earlier proceedings.
Conclusion: The enhanced fee under the amended rule did not apply to the petitioners' appeals, and the pre-amendment fee alone was payable.
Ratio Decidendi: A vested right of appeal is governed by the law in force when the original proceedings commence, and a later amendment imposing a more onerous appeal condition is not retrospective unless clearly made so by express provision or necessary intendment.