JUDGMENT : Talapatra, J. By means of the writ petition, the petitioner has challenged the order of the respondent No.3 contained in the communication dated 16.10.2015(Annexure-P/8 to the writ petition). By the said communication dated 16.10.2015, the petitioner, which is proprietorship firm, has been asked to deposit the remaining amount to the extent of Rs.8,40,000 as security for registration as transporter, which, in terms of Section 2(33) of the Tripura Value Added Tax Act, 2004, means a registered transport company, a carrier or a transporting agent operating transport business in Tripura in taxable goods. 2. The undisputed facts as emerged from the records are that the petitioner applied for registration in terms of Section 22 of the Tripura Value Added Tax Act, 2004, ‘the TVAT Act’ in short. Section 22 of the TVAT Act provides that, no transporter, carrier, or transporting agent shall operate its transport business in Tripura relating to taxable goods without being registered by the Commissioner of Taxes. For purpose of registration, every transporter is required to apply for registration to the Commissioner in the prescribed manner. After receipt of the application under subsection (2) of Section 22 of the TVAT Act, the Commissioner of Taxes shall, if he is satisfied after such enquiry as may be deemed necessary that the application is in order, register the applicant. The Commissioner may ‘for good or sufficient reason’, demand from a registered transporter or a transporter who has applied for registration, reasonable security for protection of taxes. 3. It is further not in dispute that, by the Memorandum dated 17.11.2011 (Annexure-P/4 to the writ petition), the Commissioner of Taxes in exercise of the powers conferred by Rule 12(4) of the Tripura Value Added Tax Rules, 2005, ‘TVAT Rules’ in short, determined the Security or Additional Security to be furnished by the registered dealers and the registered transporters/couriers. The said rate has also been made applicable for the new registrations of transporters/couriers. For purpose of reference, the table containing the rates in the said Memorandum dated 17.11.2011 is extracted hereunder : Classes of Transporters Amount of Security Money to be deposited in each case (Figures in Rs. The said rate has also been made applicable for the new registrations of transporters/couriers. For purpose of reference, the table containing the rates in the said Memorandum dated 17.11.2011 is extracted hereunder : Classes of Transporters Amount of Security Money to be deposited in each case (Figures in Rs. Lakh) (a) Transporters other than Couriers (b) Branch Office of Transporters other than Couriers 12.0 120 (c) Couriers 3.6 (d) Couriers (PMRY beneficiaries) 0.6 The petitioner had applied for registration as the transporter, being the courier and as such, in view of that determination as reflected in the memorandum dated 17.11.2011,on the date of application i.e. 22.04.2014 he was liable to pay the security deposit to the extent of Rs. 3.60 lacs. Rule 12(4) of the TVAT Rules further provides that, the security or additional security to be furnished by the registered dealer under section 20 or by registered Transporter under section 22 shall be determined by the Commissioner on the basis of nature of business, capital investment and taxable turnover etc. It appears that by the memorandum dated 17.11.2011 the Commissioner of Taxes has segmented the transporters for purpose of security deposit in 4(four) broad categories i.e. (a) Transporters other than couriers, (b) Branch office of transporters other than couriers, (c) Couriers and (d) Couriers (PMRY beneficiaries). 5. There is no dispute that the petitionerfirm applied for registration under the category of couriers and hence, as stated, the petitionerfirm was liable to pay the security deposit to the extent of Rs.3.60 lacs. Though the application was made on 22.04.2014, the respondents, the respondent No.2 in particular, did not take any decision on the application filed by the petitionerfirm for registration till 22.04.2015 when approval for registration was accorded. In view of the approval by the Commissioner of Taxes dated 22.04.2015, the respondent No.2 gave the following note under Note No.23 in the File No.F.UR/ST/CHVII/2015/126 : “Ask the applicant to deposit Rs.3,60,000/(rupees three lakhs sixty thousand)only through challan as security as approved by the authority.” 6. It is not further disputed that the petitionerfirm deposited Rs.3,60,000 as security on 31.07.2015 by challan. But in the meanwhile, by dint of the Memorandum No.F.16(3)TAX/2004/925175 dated 20.07.2015 (AnnexureP/7 to the writ petitioner), the Commissioner of Taxes, in exercise of the powers conferred by Rule 12(4) of the TVAT Rules, had revised the security deposit for the registered transporters and for the new registrations. But in the meanwhile, by dint of the Memorandum No.F.16(3)TAX/2004/925175 dated 20.07.2015 (AnnexureP/7 to the writ petitioner), the Commissioner of Taxes, in exercise of the powers conferred by Rule 12(4) of the TVAT Rules, had revised the security deposit for the registered transporters and for the new registrations. For purpose of reference, entries (iv), (v) and (vi) of the said memorandum dated 20.07.2015 are annexed hereto : 7. It has been clearly stated in the said memorandum that the new rate shall come into force with effect from the date of issue of the memorandum i.e. 20.07.2015. Despite that, the respondents, particularly the respondent No.3, raised the demand for additional amount as security deposit by the impugned decision contained in the communication dated 16.10.2015 (AnnexureP/8 to the writ petition). For purpose of reference the said communication is extracted hereunder : (iv) Transporters of all categories by whatever name known Rs.12,00,000.00 (v) Branch Office of Transporters of all categories by whatever name known (vi) Amendment of registration other than inclusion of branch office of transporters as mentioned at Sl.No.(v) Rs.12,00,000.00 Nil “To The Proprietor, Sree Ramkrishna Courier & Cargo Services, Barjala, Agartala Sub : In the matter of security deposit for obtaining registration of a transporter being the Courier & Cargo Services. Ref :Your application dated 24.04.2014. Dear Sir, While inviting a reference to your application as mentioned above for obtaining registration of your firm Sree Ramkrishna Courier & Cargo Servies, Barjala, Agartala, Tripura West it is stated that the amount of security deposit in respect of Cargo & Courier Services has since been refixed at Rs.1200000/(Rupees Twelve Lakhs) only vide Memo No.F.16(30)TAX/2004/925175 DATED 20.07.2015 INSTEAD OF Rs.3,60,000/and whereas your concern did not deposit the said amount of Rs.3,60,000/before introduction the Memo issued on 20.07.2015 as stated above. You are, requested to please deposit the remaining amount of Rs.8,40,000/(Rs.12,00,000/() Rs.3,60,000/)= Rs.8,40,000/as security for registration as a transporter immediately. Yours faithfully, Sd/illegible Superintendent of Taxes ChargeVII, Agartala” The petitioner has challenged the said decision/order, raising an additional demand for purpose of registration. 8. Mr. Somik Deb, learned counsel appearing for the petitioner has submitted that the registration under Section 22 of the TVAT Act is prerequisite to carry on the business of the Courier which would act as the carrier for importing taxable goods into the State of Tripura. 8. Mr. Somik Deb, learned counsel appearing for the petitioner has submitted that the registration under Section 22 of the TVAT Act is prerequisite to carry on the business of the Courier which would act as the carrier for importing taxable goods into the State of Tripura. Though the application was made on 22.04.2014 the security deposit was determined and approved on 22.04.2015 as reflected in the said Note No.23. In terms of the said demand, admittedly the petitioner deposited a sum of Rs.3,60,000 in conformity to the memorandum dated 17.11.2011, which was in force at the relevant point of consideration. 9. The respondents, by filing a counteraffidavit, has submitted that the additional security deposit has been raised in terms of the memorandum dated 20.07.2015 whereby the rate of security deposit has been revised and enhanced to Rs.12,00,000 for category of couriers. The respondents have also asserted that : “The applicant transporter has also not deposited the security amount of Rs.3,60,000/(Rupees three lakhs six thousand) [sic] on 22.04.15 and has deposited Rs.3,60,000/(Rupees three lakhs six thousand) as security money on 31.07.2015 with prospective effect security deposit for granting registration of a transport [sic] on and from 20.07.2015 shall be Rs.12,00,000/(Rupees twelve lakhs).” 10. Mr. Somik Deb, learned counsel appearing for the petitioner though submitted that he was not communicated about the determination as approved by the Commissioner of Taxes, but from the records as produced by Mr. D.C. Nath, learned counsel appearing for the respondents, it clearly transpires that the petitionerfirm was communicated and it deposited the said amount as security by way of an account payee cheque No.105510 dated 31.07.2015 on State Bank of India. That apart, the petitioner had submitted a representation to the respondent No.3 on 19.08.2015, as it is borne in the records produced by Mr. D.C. Nath, learned counsel appearing for the respondents, raising serious objection against the additional deposit, contending that : “In this instant case memorandum dated 20.07.2015 may not attract, because the approval of the instant case was prior to issuance of memorandum dated 20.07.2015”. No communication thereafter has been made to the petitionerfirm nor the registration certificate as the courier has been issued in favour of the petitionerfirm. 11. No communication thereafter has been made to the petitionerfirm nor the registration certificate as the courier has been issued in favour of the petitionerfirm. 11. The solitary question that limits the expanse of the controversy in this case is, whether the Memorandum dated 20.07.2015 (AnnexureP/7 to the writ petition) would apply in the case of the petitioner for purpose of raising additional security deposit or whether such exercise would imply the retrospective operation of the said memorandum dated 20.07.2015? 12. Ordinarily, unless a contrary intention appears, a legislative act is presumed not to be intended to have a retrospective operation. It is based on the principle lexprospicitnonrespicit, meaning, the law looks forward, not backward. On the principle of fairness, unless the piece of legislation provides by way of expressed provision of its operation retrospectively that cannot be allowed to operate retrospectively. When the memorandum dated 20.07.2015 itself provides that, that would operate prospectively, by means of no interpretation or by any manner the said memorandum can be applied retrospectively. In this case, the demand as raised by the respondent No.3 is an apparent outcome of revising the earlier determination of the security deposit in terms of the memorandum dated 17.11.2011, which was in force at the relevant time of consideration. When the context makes the meaning of a word quite clear it becomes unnecessary to search for and select a particular meaning for giving a different interpretation. Note No.29, which appears to be the basis of the impugned decision/order as reflected in the communication dated 16.10.2015, may be extracted hereunder: NOTE NO.29 Ref. Note No.27 & 28 ante of linked file of Superintendent of Taxes, chargeVII, Agartala. This is regarding registration of a transporter M/S Sree Ramkrishna Courier & Cargo Service, Barjala, Agartala 2. The matter is examined and the observations are as follows : (i) The applicant transporter was asked to deposit security amounting to Rs.3,60,000.00 after obtaining approval of the Commissioner of Taxes, on 22.04.2015. (ii) The applicant deposited Rs.3,60,000.00 on 31.07.2015 and submitted challan of payment. (iii) The security deposit for registration of transporter of all categories is refixed at Rs.12.00 lakhs vide Memo No.F.16(30)TAX/2004/925175 dated 20th July 2015 with prospective effect. (ii) The applicant deposited Rs.3,60,000.00 on 31.07.2015 and submitted challan of payment. (iii) The security deposit for registration of transporter of all categories is refixed at Rs.12.00 lakhs vide Memo No.F.16(30)TAX/2004/925175 dated 20th July 2015 with prospective effect. (iv) The application for registration of the transporters was not disposed till date and he has also not deposited the security amount of Rs.3,60,000.00 as asked for on 22.04.2015 and has deposited Rs.3,60,000.00 as security on 31.07.2015 with prospective effect security deposit for granting registration of a transporter on and from 20.07.2015 shall be Rs.12.00 lakhs. (v) Therefore, the applicant is required to deposit Rs.12.00 lakhs as security for registration as a transporter.” 13. From a bare reading of the said Note No.29, it becomes abundantly clear that the only reason for raising the additional demand for security is that the applicant, the petitionerfirm had deposited Rs. 3,60,000 on 31.07.2015, after the new rate of security deposit has been introduced by the memorandum dated 20.07.2015. In the records as produced by the respondents or in the counteraffidavit no explanation has been given as to why the application for registration which was filed on 24.04.2014 was kept pending till 22.04.2015 when the petitionerfirm was asked to deposit the security for registration. When after inquiry, the petitionerfirm was found competent to have the registration certificate as the transporter (courier), though belatedly on 22.04.2015, the demand for security deposit was made and as such the relevant date for purpose of determining the rate of security deposit shall invariably be 22.04.2015, not 31.07.2015. By way of applying the new rate in the case of the petitionerfirm, we have no doubt in our mind that the respondents have given retrospective effect of the memorandum dated 20.07.2015, which according to us, in the context of this case, cannot be sustained. Hence, the impugned decision/order as reflected in the communication dated 16.10.2015 (AnnexureP/8 to the writ petition), is interfered with and set aside. The respondents, the respondent No.2 in particular, are directed to issue the registration certificate for transporter (courier) in favour of the petitioner within a period of 30(thirty) days from today. 14. With this observation and direction, this writ petition stands allowed to the extent as indicated above. However, in the circumstances, there shall be no order as to costs. The records as produced on 22.06.2016 be returned to Mr. D.C. Nath, learned counsel for the respondents.