Accrued tax liability survives partial repeal under the general savings clause, allowing proceedings to continue.

An adaptation order making the Excess Profits Tax Act, 1940 inapplicable in Bellary district was treated in substance as a repeal for that area, so section 6 of the General Clauses Act, 1897 applied to preserve accrued rights and liabilities. A liability to excess profits tax arises at the close of the chargeable accounting period, not only on assessment. Because the liability had already accrued before the Act ceased to apply in Bellary, section 6(c) saved it and proceedings under section 15 could continue against the assessee.

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Issues: Whether proceedings under section 15 of the Excess Profits Tax Act, 1940 could continue in Bellary district after the Act ceased to apply there by reason of the adaptation order, and whether the liability to pay excess profits tax had already accrued so as to be preserved by section 6(c) of the General Clauses Act, 1897.

Analysis: The adaptation order had the effect of making the Act inapplicable in Bellary district, which amounted in substance to a repeal for that area. Section 6 of the General Clauses Act, 1897 applies not only to a total repeal but also to a partial repeal or repeal of part of an enactment. The liability to excess profits tax arose at the close of the chargeable accounting period and not only when assessment was completed. Since the charge had already arisen before the Act ceased to apply in Bellary district, the accrued liability was saved by section 6(c) notwithstanding the later adaptation.

Conclusion: The notice under section 15 remained valid and the appellants continued to be liable to be proceeded against; the issue was decided against the assessee.

Final Conclusion: The accrued tax liability survived the cessation of the Act's application in the district, and the challenge to the proceedings failed.

Ratio Decidendi: A tax liability that has accrued at the end of the chargeable period is preserved by the general savings clause on repeal, including a repeal operating only for part of the territory or for part of an enactment.

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