Prospective tax amendment under section 184(7) cannot deny registration continuity for an earlier assessment year.

An amendment to section 184(7) governing the filing of a declaration for continuation of registration could not be applied to assessment year 1970-71 because it was expressly brought into force only from 1 April 1971. Since the filing obligation arose prospectively, failure to satisfy the amended requirement could not be used to deny continuation of registration for a period governed by the unamended provision. The rectification request under section 154 was therefore rightly rejected, and the amended provision did not govern the assessee's case.

---

---

Issues: Whether the amended provisions governing the filing of a declaration for continuation of registration under section 184(7) of the Income-tax Act, 1961 applied to the assessment year 1970-71.

Analysis: The declaration for continuation of registration was filed after the amendment came into force on 1 April 1971, and the amendment itself was expressly made effective from that date. The filing requirement could not be applied to an earlier assessment year so as to defeat continuation of registration for a period governed by the unamended provision. The rectification request under section 154 was therefore correctly rejected by the appellate authorities and the Tribunal, which held that the amended requirement did not govern the case.

Conclusion: The amended section 184(7) did not apply to the assessee's case, and continuation of registration could not be denied on that basis.

Ratio Decidendi: An amendment expressly brought into force prospectively cannot be applied to deny a statutory benefit for an earlier assessment year where the obligation it creates was not yet in force.

---