Retrospective tax amendment controls filing deadlines, so interest could not be levied on the earlier extended due date.

Retrospective amendment under the Karnataka Agricultural Income-tax Act, 1957 altered the filing due date for the relevant previous year, and the earlier extension granted by the assessing authority became ineffective once the amended regime applied. Interest under the proviso to section 61 had to be read with the amended due date under section 18, so delay could not be treated by reference to the superseded extended period. The commentary also relies on the principle that tax and incidental imposts require authority of law. On that basis, interest was treated as not payable and the levy was quashed in favour of the assessee.

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Issues: Whether interest was leviable on the delayed filing and payment of agricultural income-tax return after the retrospective amendment to the Karnataka Agricultural Income-tax Act, 1957.

Analysis: The amendment made by Act No. 14 of 1983 operated retrospectively for the relevant previous year and altered the time-limit for filing returns. Once the amended regime applied, the earlier extension granted by the assessing authority became superfluous. The liability to pay interest under the proviso to section 61 had to be read with the amended due date under section 18, and interest could not be imposed as though the extended time granted earlier still controlled the matter. The principle that tax and incidental imposts cannot be collected without authority of law also supported the assessee's position.

Conclusion: Interest was not payable and the levy of interest was quashed, in favour of the assessee.

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