JUDGMENT :

In these writ petitions, the issue that arises for consideration is the legality of the notices and assessment orders issued to the petitioners in connection with the assessment under the Kerala Value Added Tax Act [hereinafter referred to as the 'KVAT Act'] for the assessment years 2010-11 and 2011-12. The notices and orders are impugned, inter alia, on the ground that the authorities concerned did not have the jurisdiction to issue them since the amendments introduced to Section 25 (1) of the KVAT Act, through the Kerala Finance Acts of 2017 and 2018, notified through gazette notifications dated 19.06.2017 and 31.03.2018 respectively, did not contemplate a retrospective operation of the amended provisions.

2. Before framing the issues that arise for adjudication in these writ petitions, it would be apposite to refer to the legislative exercises that were undertaken in respect of Section 25 (1) of the KVAT Act during the period between 2016 and 2018. Section 25 (1) as it stood immediately prior to its amendment with effect from 01.04.2017 read as follows:

“25. Assessment of escaped turnover:-(1) Where for any reason the whole or any part of the turnover of business of a d