Article 277 does not freeze tax machinery; Parliament may shift pre-Constitution tax assessment to Income-tax officers.

Article 277 preserved the levy of pre-Constitution State taxes, but it did not freeze the machinery for their assessment and collection. Parliament could therefore validly authorise officers appointed under the Indian Income-tax Act, 1922, to assess income-tax and super-tax on income accruing before 1 April 1950 in Mysore under the Indian Finance Act, 1950. The constitutional objection that only the pre-Constitution State machinery could act was rejected, because Article 277 did not bar a change in administrative authority. The assessments were sustained and the challenge failed.

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Issues: Whether the Income-tax Officer appointed under the Indian Income-tax Act, 1922 could assess income-tax and super-tax on income accruing before 1 April 1950 in Mysore under Section 13 of the Indian Finance Act, 1950, and whether Article 277 of the Constitution prohibited Parliament from providing for levy and collection through such authorities.

Analysis: The challenge on retrospective operation was governed by the contemporaneous constitutional ruling relied upon by the Court. On Article 277, the provision saved the continuance of taxes lawfully levied before the Constitution and did not require that they continue to be assessed and collected only by the pre-Constitution State machinery. The Court held that Parliament could validly provide for a changeover to officers appointed under the Indian Income-tax Act, 1922, and that such a course was consistent with efficient administration and not forbidden by Article 277.

Conclusion: The Income-tax Officer had jurisdiction to assess the appellant for the relevant pre-Constitution period, and the constitutional challenge failed.

Final Conclusion: The appeals were liable to fail and the assessments were sustained.

Ratio Decidendi: Article 277 preserves the levy of pre-Constitution State taxes but does not freeze the assessment and collection machinery, and Parliament may lawfully provide for their administration through authorities constituted under the Indian Income-tax Act, 1922.

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