Accrued tax liability survives statutory omission where the amending law shows no contrary intent.

Liability to pay annuity deposit that had accrued before omission of the enabling provisions from the Income-tax Act remained enforceable after the amendment. The Court applied Section 6 of the General Clauses Act, 1897, holding that an accrued liability is not extinguished merely because the statutory provision creating the obligation is later omitted, unless the amending law shows a contrary intention. It distinguished authorities involving true repeal or different statutory settings. The challenge therefore failed, and the accrued tax liability continued to bind the assessee despite the subsequent omission.

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Issues: Whether the liability to pay annuity deposit, which had accrued before the omission of the relevant provisions from the Income-tax Act, 1961, could still be enforced after the amendment, and whether Section 6 of the General Clauses Act, 1897 applied to save the accrued liability.

Analysis: The liability had arisen before the relevant provisions were omitted with effect from 1 April 1967. The omission was not treated as having retrospective effect, and there was nothing in the amending Finance Act to indicate an intention contrary to the ordinary operation of Section 6 of the General Clauses Act, 1897. The Court distinguished authorities dealing with true repeal or different statutory contexts and held that a liability already accrued is not extinguished merely because the enabling provision is later omitted.

Conclusion: The accrued liability to pay annuity deposit remained enforceable notwithstanding the subsequent omission of the relevant provisions, and the petitioner's challenge failed.

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