Kumar Rajaratnam, J.—In all these appeals the constitutional validity of the Explanation to Section 26(4) of the Karnataka Agricultural Income Tax Act, 1957, introduced retrospectively with effect from April 1, 1975, by the Karnataka Taxation Laws (Second Amendment) Act, 1997 (Act No. 18 of 1997), falls for determination.

2. The provisions of Section 26(4) and the Explanation thereto of the Karnataka Agricultural Income Tax Act, 1957, as amended by Act 18 of 1997 (hereinafter referred to as the Act), read as follows :

"26. (4) Where any business through which agricultural income is received by a company, firm or association of persons is discontinued or any such firm or association is dissolved in any year, any sum received after the discontinuance or dissolution shall be deemed to be income of the recipient and charged to tax accordingly in the year of receipt, if such sum would have been included in the total income of the person who carried on the business had such sum been received before such discontinuance or dissolution.

Explanation.--For the removal of doubts, it is hereby declared that where before the discontinuance of such business or dissolution of a firm or associ