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Assessed

Assessed Income Tax Act, 1922, Section 18A (3), 3(B) In Section 18A(1) the expression "assessed" is used without any qualification or restriction as to whether the assessment should be a regular assessment or any other type of assessment under the Act. It is also manifest that in Section 18A sub-section (5) the two expressions "provisional assessment" and "regular assessment" are expressly mentioned. The expression "regular assessment" is also repeatedly used in Section 18A, sub-sections (6), (7), (8) and (9). We see, therefore, no warrant for restricting the meaning of the word "assessed" in S. 18A (1) so as to include only a "regular assessment" under section 23 of the Act. There is no reason why Parliament did not add the word "regularly" in the sub-section so as to qualify the word "assessed". Since there is no such qualification, the word "assessed" in section 18A (3) should be read in its ordinary sense as including every kind of assessment including a provisional assessment under section 28B of the Act. (I.T. Officer, Kanpru v. Mani Ram, AIR 1969 SC 543 (547)
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