Profession tax liability arises on the charging provision itself; expiry of a temporary ordinance does not make prior payments refundable.

Under a taxing statute, the charge itself creates liability and assessment only quantifies it; for persons within the notified classes, profession tax arose automatically and was not conditioned on prior registration or assessment. The provisions for registration, returns, salary deduction and assessment were machinery provisions, not conditions precedent to tax incidence. Amounts paid while the temporary ordinance was in force were made against accrued liabilities, and the ordinance's expiry did not extinguish those liabilities absent contrary intention. The refund claim therefore failed.

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Issues: Whether profession tax deducted and deposited during the currency of a temporary taxing ordinance became refundable on the expiry of the ordinance, and whether the liability to pay the tax depended upon registration or assessment.

Analysis: The charging provision made liability to profession tax arise automatically for persons within the notified classes, while the assessment machinery only quantified an already existing liability. The provisions regarding registration, return filing, deduction from salary or wages, and assessment did not make the incidence of tax conditional upon prior registration or assessment. Amounts deposited while the ordinance remained in force were therefore payments made against liabilities that had already accrued. The expiry of a temporary taxing measure does not, in the absence of contrary intention, extinguish liabilities or obligations incurred during its life.

Conclusion: The liability to profession tax arose under the charging provision itself and did not depend on registration or assessment. The amount paid during the life of the ordinance was not refundable merely because the ordinance later expired, and the claim for refund failed.

Ratio Decidendi: Under a taxing statute, the charge creates the liability and assessment only quantifies it; liabilities incurred under a temporary taxing enactment survive its expiry unless a contrary intention is expressed.

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