Uniform return-filing deadline upheld as a valid procedural amendment despite claimed hardship and constitutional challenge.

The Karnataka Agricultural Income-tax Act amendment reducing the return-filing period to four months was treated as a uniform procedural change and not an unconstitutional restriction. The High Court's reasoning was that the new deadline was not unreasonably short, did not by itself impair the right to carry on trade or occupation, and could not be struck down merely because later tax-law changes might occur before assessment. Claims of special hardship for tea companies and assessees needing audit documents were not shown with sufficient legal prejudice to invalidate the provision.

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Issues: Whether the amendment to section 18(1) of the Karnataka Agricultural Income-tax Act, reducing the time for filing returns to four months from the end of the previous year, was unconstitutional on the ground of hardship and unreasonable restriction.

Analysis: The amended provision applied uniformly to all assessees and merely altered the time for filing returns. The Court held that four months was not an unreasonably short period and did not impose an unconstitutional restriction on the right to carry on trade or occupation. The possibility that changes in tax law may occur before assessment was not, by itself, a ground to invalidate a procedural amendment intended to secure uniformity. The Court further held that tea companies and companies requiring audit documents were not shown to suffer such legal prejudice as would justify striking down the provision.

Conclusion: The challenge to the amended return-filing requirement failed and the provision was upheld against the constitutional attack.

Final Conclusion: The writ petitions were dismissed, and the amended filing-time requirement under the Agricultural Income-tax law was sustained.

Ratio Decidendi: A procedural amendment fixing a uniform time-limit for filing returns is valid unless it imposes an unreasonable restriction or demonstrated unconstitutional hardship; speculative difficulty arising from possible future changes in law does not invalidate it.

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