Municipal tax amendments apply only prospectively within the current official year, not retrospectively for earlier expired years.

An amendment to a municipal assessment list under Section 82(3) of the Bombay Municipal Boroughs Act, 1925 operates only from the commencement of the current official year in which the amendment is made. Construing "current official year" in its statutory context, the court held that enhanced tax can be recovered only for the proportionate remainder of that year, not for earlier expired official years. That reading was supported by the annual character of assessment under Sections 81(6) and 84, which confine the authenticated list's effect to the year in force and treat taxation year by year. The contrary retrospective construction was rejected as inconsistent with the statutory scheme.

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Issues: Whether an alteration made under Section 82(3) of the Bombay Municipal Boroughs Act, 1925 can operate retrospectively so as to authorize levy of enhanced tax for earlier official years, or whether it takes effect only from the commencement of the current official year in which the amendment is made.

Analysis: The expression "current official year" in Section 82(3) was construed in its temporal setting to mean the official year then running when the assessment list is amended. The language of the subsection, read as a whole, links the effective date to the earliest day in that year on which the relevant circumstances existed and then limits recovery to the proportionate remainder of that same year. That construction is reinforced by Section 81(6), which gives conclusiveness to the authenticated assessment list only for the official year in which it is in force, and by Section 84, which treats the list as applicable year by year. The contrary view, which would permit recovery for earlier expired years, was held inconsistent with the statutory scheme and with the annual basis of the tax.

Conclusion: The alteration under Section 82(3) does not authorize levy of enhanced tax for prior expired official years and becomes effective only from the commencement of the current official year in which the amendment is made; the answer is against the Municipality and in favour of the assessee.

Ratio Decidendi: In a municipal tax regime based on annual assessment, an amendment to the assessment list under Section 82(3) can take effect only within the current official year in which the amendment is made, and cannot be used to impose tax retrospectively for earlier concluded years.

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