Statutory tax exemption survived until 31 March 2002, so later omission of the provision did not create liability for earlier income.

A statutory exemption continued for income derived up to 31 March 2002 despite the later omission of section 50 of the Small Industries Development Bank of India Act, 1989 from 1 April 2002. On that basis, the assessee was not liable to income tax for assessment year 2002-03 on the relevant income, and the High Court found no substantial question of law arising from the Tribunal's view. The appeal therefore failed and was dismissed.

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Issues: Whether the assessee was liable to pay income tax for assessment year 2002-03 in view of the omission of section 50 of the Small Industries Development Bank of India Act, 1989 with effect from 1 April 2002.

Analysis: The appeal challenged the Tribunal's view on the taxability of the assessee for assessment year 2002-03. The omission of section 50 took effect from 1 April 2002, and the exemption continued for income derived up to 31 March 2002. The Tribunal's view was consistent with the earlier decision relied upon by it, and no substantial question of law arose.

Conclusion: The assessee was not liable to pay income tax on the relevant income for the period ending 31 March 2002, and the question was answered against the Revenue.

Final Conclusion: The appeal failed and stood dismissed because the statutory exemption remained effective for the relevant period and the matter did not raise any substantial question of law.

Ratio Decidendi: Where a statutory exemption continues until a specified date, liability to tax for income earned before that date is not created by a later omission of the exempting provision.

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