Repeal and saving provisions preserve pending tax proceedings and determine appellate forum by the date of the impugned order.

The repeal and saving provisions of the Kerala Agricultural Income-tax Act, 1991 preserve prior assessments and pending proceedings, while the available remedy and forum are determined with reference to the date of the impugned order. Applying that framework, the Tribunal was justified in entertaining the second appeal after the 1991 Act came into force because the matter fell to be dealt with under the post-commencement appellate structure. The challenge to the Tribunal's jurisdiction and admission of the appeal therefore failed.

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Issues: Whether the second appeal before the Tribunal was properly entertained and disposed of after the coming into force of the Kerala Agricultural Income-tax Act, 1991, in light of the repeal and saving provisions.

Analysis: The revisions arose from best judgment assessments made under section 18(4) of the Kerala Agricultural Income-tax Act, 1950. The assessee's appeals were rejected as not maintainable by the Appellate Assistant Commissioner, and the Tribunal thereafter entertained the matter under the 1991 Act. The deciding factor was the effect of section 99(1) and section 99(4) of the Kerala Agricultural Income-tax Act, 1991, which save prior actions and continue pending proceedings as if under the earlier law, while the remedy and the forum are to be understood with reference to the date of the impugned order. The Tribunal was therefore justified in treating the matter as governed by the post-commencement appellate structure under sections 72 and 74 of the 1991 Act.

Conclusion: The second appeal was validly admitted and dealt with by the Tribunal, and the challenge to that course failed.

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