Under the Indian Constitution, the legislative power to make a law for imposing a tax is divided between the Union and the States by means of specific Entries in the Union and State Legislative Lists in Schedule VII. The residuary power of taxation (as in general legislation) belongs1 to Parliament and in this regard Entry 97 of List I provides as follows: "Any other matter not enumerated in List II or List III including any tax not mentioned in either of those lists." This entry is further reinforced by Art. 248 which vests in "Parliament exclusive power to make any law with respect to any matter not enumerated in the Concurrent List or the State List." This includes the power to levy residuary taxes along with residuary powers of legislation. In Hari Krishna Bhargava v. Union of India2, the provisions of the Income-tax Act, 1961, relating to annuity deposits were challenged before the Sup ....