Prospective operation of tax amendments prevents retrospective application of the amended market value definition to earlier assessments.

The amended definition of "market value" inserted into the Chhattisgarh Entry Tax law was held to operate prospectively from 01.04.2014 and not to govern assessments for earlier periods. The Court applied the settled rule that tax liability is determined by the law in force in the relevant assessment year unless retrospective effect is clearly expressed or necessarily implied. As the amendment and the consequential circular took effect only from the stated future date, the pre-amendment law continued to apply to periods before that date, and the impugned assessments and related demand notices were quashed.

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Issues: Whether the amended definition of "market value" inserted by Section 2(fff) of the Chhattisgarh Entry Tax (Amendment Act), 2014, which came into force from 01.04.2014, could be applied to fresh assessments for periods prior to that date.

Analysis: The assessment years in dispute preceded the commencement of the amended definition. The Court followed the earlier coordinate Bench decision holding that the amendment and the consequential circular were prospective in operation. It applied the settled principle that tax liability is governed by the law in force in the relevant assessment year unless a contrary intention is expressly or by necessary implication indicated. Since the amendment became operative only from 01.04.2014, the earlier law continued to govern periods before that date.

Conclusion: The amended definition of "market value" could not be applied retrospectively to assessments relating to periods prior to 01.04.2014, and the pre-amendment law was applicable.

Final Conclusion: The impugned assessments, revisional orders, and royalty-related demand notices were quashed, and the writ petitions were allowed.

Ratio Decidendi: A statutory amendment in fiscal law operates prospectively when it is expressly brought into force from a future date, and the assessment must be made according to the law prevailing in the relevant assessment year unless retrospective application is clearly provided.

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