ISSUE:
Whether the State Government has the authority to retrospectively apply enhanced license fees on the balance stock of intoxicants held by a licensee after the expiry of the license period?
Whether the balance stock of liquor, already subjected to the license fee at the time of its initial purchase, can be subjected to an enhanced fee retrospectively?
RULE:
Subordinate legislation, such as rules made by a delegate, can be given retrospective effect if explicitly or implicitly authorized by the parent statute.
The principles of equity and consistency in taxation justify applying enhanced fees to surplus stock retained by the licensee, ensuring parity with other vendors operating under the revised fee structure?