Mid-year tax amendment requires period-wise computation of liability under the law in force before and after the change.

Where a tax statute is amended mid-year to change the turnover threshold, liability must be worked out separately for the pre-amendment and post-amendment periods. The turnover for the full financial year may be examined to see whether the charge is attracted, but the actual levy must be computed period-wise under the provision in force for each segment of the year. The unamended provision applies to the earlier period, and the amended provision applies after the amendment. The Tribunal's contrary view was not fully sustainable, and the assessment had to be recomputed on a bifurcated basis.

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Issues: Whether, on a mid-year amendment to the turnover threshold under the Tamil Nadu Additional Sales Tax Act, 1970, the assessee's liability had to be determined separately for the pre-amendment and post-amendment periods, and whether the demand based on the Tribunal's view could stand.

Analysis: The governing principle is that where a financial year is split by a statutory amendment changing the taxable turnover threshold or the applicable rate, the liability must be worked out with reference to the law in force during each relevant period. The pre-amendment period is governed by the unamended provision, while the post-amendment period is governed by the amended provision. The Court applied this principle to the assessment year in question and held that the turnover for the whole year must first be considered to determine whether the charge is attracted, but the actual levy must be computed period-wise in accordance with the threshold and rate prevailing before and after the amendment.

Conclusion: The Tribunal's view was not sustainable in full. The assessee's liability had to be recomputed by applying the unamended provision for the pre-amendment period and the amended provision for the post-amendment period.

Final Conclusion: The assessment was required to be redone on a bifurcated basis for the two periods of the financial year, and the matter was left to the Assessing Officer for fresh computation of liability.

Ratio Decidendi: When a tax statute is amended during the course of a financial year, the chargeability and rate of tax must be determined by applying the law in force for each relevant segment of that year, without disturbing the basic liability otherwise attracted for the year as a whole.

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