Judgment :- 1. The assessee retired as the Chief Justice of this court in 1960. In respect of his income-tax assessments for the Assessment years 1964-65,1965-66 and 1966 67 the question arose whether Annuity Deposit was payable under the provisions of Chapter XXII-A of the Income-tax Act, 1961, introduced by the Finance Act, 1964. Over-ruling the assessee's contention, the Income-fax Appellate Tribunal found that the Annuity Deposits were payable. It referred the following question of law under S.256 (1) of the Income¬iax Ad, for determination and opinion of this Court: "Whether the Income-tax Officer on the date he completed the assessments for assessment years 1964-65, 1965 66 and 1966 67 was, after the repeal by way of omission of S.280 K and 280 T of Income-tax Act, 1961 with effect from 141967 competent to determine for these three assessment years the amount of annuity deposit required to be made by the assessee." 2. Chapter XXII-A dealing with Annuity Deposit was introduced in the Income-tax Act by the provisions of the Finance Act, 1964, with effect from 141964. We may briefly notice the provisions of this Chapter. S.280-A provides that the provisions of the Chapter shall apply to every person whether an individual, a Hindu undivided family, an unregistered firm, or an association of persons or body of individuals whether incorporated or not, or an artificial juridical person. S.280-B deals with definitions. S.280-C is important and is as follows: "280 C. Requirement as to annuity deposit (1) Where any Central Act enacts that any person to whom the provisions of this Chapter apply shall make for any assessment year an annuity deposit with the Central Government at any rate or rates, such person shall make such deposit at that rate or those rates in accordance with, and subject to the provisions of this Chapter in respect of the adjusted total income of the previous year or previous years, as the case may be. (2) In respect of the adjusted total income in relation to which an annuity deposit shall be made is to be made under sub-section (I), such deposit shall be made in advance in accordance with the provisions of S.280-E to 280-I." S. 280-D provides for repayment of Annuity Deposit. 280-E deals with computation of advance deposit 280-F provides for an order by Income-tax Officer. 280-E deals with computation of advance deposit 280-F provides for an order by Income-tax Officer. Under this provision, the Income-tax Officer was enabled to require an assessee to make an advance deposit in accordance with S.280-E. S.280-G provides for instalments of advance deposits; 280-H. for estimate by depositor; 2804, for commission receipts; and 280-J, for Annuity deposit on the basis of self-assessment. Then follows S.280-K which is as follows: "280-K Annuity deposit on the basis of provisional or regular assessment. At the time of making a provisional assessment under S.141 or a regular assessment, or as soon thereafter as may be, the Income-tax Officer shall, by order in writing, determine the amount of annuity deposit, if any, required to be made by the depositor on the basis of the income so assessed after taking into account the amount of annuity deposit, if any, already made by him in respect of that assessment year." We omit several other provisions except S.280-R and 280-T on which the assessee has placed reliance. These provisions are: "280-R. Penalty for failure to make deposit. (1) If any person who is liable to make an annuity deposit under this Chapter fails to make such deposit within the time specified therefor, the Income-tax Officer may direct that the depositor shall pay by way of penalty an amount not exceeding one-half of the annuity deposit which be is liable to make. (1) If any person who is liable to make an annuity deposit under this Chapter fails to make such deposit within the time specified therefor, the Income-tax Officer may direct that the depositor shall pay by way of penalty an amount not exceeding one-half of the annuity deposit which be is liable to make. (2) If the Income-tax Officer, in the course of any proceedings in connection with the regular assessment is satisfied that any depositor (a) has furnished under S.280-H an estimate of advance deposit to be made by him which he knew or had reason to believe to be untrue, or (b) has without reasonable cause failed to furnish an estimate of advance deposit to be made by him in accordance with the provisions of sub-section (3) of S.280-H, he may direct that such depositor shall pay by way of penalty a sum (i) which, in the case referred to in clause (a), shall not exceed half the amount by which the advance deposit actually made during the financial year immediately p recced ing the assessment year under the provisions of S.280-E to 280-1 falls short of (1) seventy-five per cent of the annuity deposit required to be made on the basis of income assessed by way of regular assessment (such deposit being calculated at the rates in force in the financial year immediately preceding the assessment year),or (2) where a notice under S.280-F was issued to the depositor, the deposit require to be made thereunder, whichever is less; and (ii) which in the case referred to is clause (b), shall not exceed half, the amount equal to the seventy-five percent, referred to in clause (i)(1). (3) No order imposing a penalty under this section shall be made unless the assessee has been heard, or has been given a reasonable opportunity of being heard. x "280-T. Recovery of arrears of deposit and penalty. For the removal of doubts it is hereby declared that any arrear of annuity deposit and any penalty imposed under this Chapter shall be recoverable in the manner provided in Chapter XVII-D for recovery of arrears of tax." The provisions relating to Annuity Deposits go upto 280-X. 3. By the Finance Act, 1966, the provisions of S.280-K, R and T were omitted with effect from 141967. By the Finance Act, 1966, the provisions of S.280-K, R and T were omitted with effect from 141967. The determination of the Annuity Deposit payable by the assessee was made only by the assessment orders dated 28 31964, 91 1970 and 7111970. 4. The contention on behalf of the assessee was that as the three S.280-K, 280-R and 280-T had been omitted, the Annuity Deposit Scheme had become unworkable. The "omission" of the three Sections, it was said, would not constitute a repeal of the said provisions, so as to attract Ss 6(c) of the General Clauses Act, 1897; and therefore the Income-tax Officer had no right or power to determine the Annuity Deposit payable. The Tribunal following the decision of the Madras High Court in J. K. K.Angappan v. Income-tax Officer (94 ITR. 397) held that the omission of the three Sections, and, in particular, or S.260-K of the Act, amounted, in effect and in substance, if not, in fact, to a repeal, that S.6(c) of the General Clauses Act was therefore attracted, and that despite the assessment having been made in 1969 it was open to the officer to determine the Annuity Deposit, and take it into account in making the assessment The correctness of this view has been canvassed in the question of law referred for our opinion. 5. We think that the Tribunal was correct in its conclusion. We have referred to the provisions of Chapter XXII-A of the income-tax Act. S.280-C is practically in the position of a charging Section which makes it obligatory on the persons concerned to make the annuity Deposit at the rate or rates prescribed "in accordance with and subject to the provisions of this Chapter". Mark the words that the liability is only to make the Deposit "in compliance with the provisions of the Chapter". The liability being there, we do not think its practical enforcement is in any way affected by the commission of the three Sections, namely, S.280-K., R and T. The omission of the latter two Sections appear to us to be quite inconsequential. Considerable stress was laid on S.280-K; and it was argued that this was the vital provision in regard to the enforcement of the Annuity Deposit Scheme and that in the absence of this Section, determination and demand of Annuity Deposit by the Income-tax Officer was impossible. We are unable to agree. Considerable stress was laid on S.280-K; and it was argued that this was the vital provision in regard to the enforcement of the Annuity Deposit Scheme and that in the absence of this Section, determination and demand of Annuity Deposit by the Income-tax Officer was impossible. We are unable to agree. The obligation to make the Deposit being there under S.280-C, power under S 280 K. given to the Income-tax Officer to determine the amount of Annuity Deposit by making a provisional assessment under S.141 or a regular assessment under S.143, appears to us to be quite a redundant and a supererogatory power. Even in the absence of such an express provisions the Officer is bound to have this power under the provision, of the Income-tax Act under which he has to proceed to make a regular assessment, (the provision for provisional assessment has been deleted with effect from 14 1971). In making the assessment, the officer is bound to take into account the income derived from all sources and to give credit to all deductions to which the assessee is entitled, under the appropriate statutory provisions. This would be sufficient to clothe the Officer with the power to take into account the Annuity Deposit paid by the assesses and to give appropriate deduction for the same. We are of the opinion that despite the omission of the three Sections by the Finance Act of 1966, from Chapter XXII-A of the Indian Income-tax Act, the rest of the Sections are quite effective and operative to enforce the Scheme for payment of Annuity Deposit and to make the determination of the same by the officer still possible. 6. We also feel that the view taken by the Madras High Court in J. K. K. Angappan v. Income-tax Officer (94 ITR. 397), is responsible and acceptable. S.3 (19) of the General Clauses Act defines, the term "enactment" as follows: "3. In this Act, and in all Central Acts and Regulations made after the commencement of this Act, unless there is anything repugnant in the subject or context, (19) 'enactment' shall include a Regulation 'as hereinafter defined) and any Regulation of the Bengal, Madras or Bombay Code, and shall also include any provision contained in any Act or in any such Regulation as aforesaid: And S.6 (c) of the Act reads: "6. Where this act, or any Central Act or Regulation made after the commencement of this Act, repeals any enactment hitherto made nor hereinafter to be made, then, unless a different intention appears, the repeal shall not (c) affect any right, privilege, obligation or liability acquired, accrued or incurred under any enactment so repealed; or The result of the combined operation of these provisions is that repeal of an enactment includes repeal of any provision contained therein; and once such repeal takes place, the consequence provided by S.6 (c) of the Act is bound to follow and rights and liabilities acquired or accrued are kept alive to be enforced in appropriate proceedings, even subsequent to repeal. 7. We are accordingly of the opinion, that the view taken by the Tribunal was correct. We answer the question referred in the affirmative, that is against the assessee and in favour of the Revenue. There will be no order as to costs. A copy of this judgment under the signature of the Registrar, and the seal of this Court, will be forwarded to the Income-tax Appellate Tribunal, Cochin Bench, as required by law.