Meaning of “Assessed and reassessed “

Case Name : Dy. Cit vs. Alok banerjee 

Citation : [2008] 111 itd 339 (all.)

Court : Allahabad high court

Section : 147

Meaning : The words ‘assessed’ and ‘reassessed’ in section 147 do not really mean “addition” to the total income. The word “assessed” means to ascertain or to fix the amount of tax to be paid, to make an evaluation or official estimate of property for the purposes of taxation. The word “assessed” is a comprehensive word in taxing statute. It often means the computation of income of the assessee, the determination of tax payable by him and whole of the procedure for making the assessment and for collecting and recovering of tax. The word “assessment” has been used in its widest connotation and includes the procedure for declaration and imposition of tax liability and the machinery for enforcement thereof including a proceeding for imposition of penalty.

The words “assessed” and “reassessed” in this section only refer to the process of assessment and reassessment i.E., Evaluation and not final act of addition.

Case Name : Praful chunilal patel vs. M.J. Makwana, asstt. Cit 

Citation : [1998] 148 ctr (guj.) 62

Court : Gujarat high court

Section : 147

Meaning : The word ‘reassess’ refers to a situation where an assessment is already made, but it is sought to be reassessed on the basis of this provision.

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