Assessment Income Tax Act, 1922, Section . 27 There is no doubt that the word "assessment" does have subject to the context a very wide meaning. The Privy Council in Commr. of Income Tdax, Bombay v. Khemchand Ramdas, (1938) 6 ITR 414 at p. 423 : (AIR 1938 PC 1754 at p. 179) observed : "In order to answer them, it is essential to bear in mind the method prescribed by the Act making an assessment to tax, using the word assessment in its comprehensive sense as including the whole procedure for imposing liability upon the tax payer." In A.N. Lakshman Shenoy v. Income-tax Officer, Ernakulam, (1958) 34 ITR 275 at p. 291 : (AIR 1958 SC 795 at p. 803) this Court held : "Now the question is in what sense has the word 'assessment' been used in S. 13(1) of the Finance Act, 1950. Two circumstances may be noticed at once. The long title says that the Finance Act, 1950, is an Act to give effect to the financial proposals of the Central Government for the year beginning on April 1, 1950, and in section 13(1) the collocation of the words is "levy, assessment and collection of income tax". In our opinion, both these circumstances point towards a comprehensive meaning; for it could not have been intended, as part of the proposal of the Central Government, that those whose income had totally escaped assessment should be liable but those who had been under-assessed should go scot free. We can see nothing in the words of the section which would justify such a distinction; we say this quite apart from the argument that Section 13(1) should be interpreted in consonance with the financial agreement entered into between the Rajpramukh and the President, an argument to which we shall presently advert. Moreover, the collocation of the words, "levy, assessment, and collection" indicates that what is meant is the entire process by which the tax is ascertained demanded and realized." In C.A. Abraham v. Income-tax Officer, Kottayam, (1961) 41 ITR 425 at pp. 429-30 : (AIR 1961 SC 609 at p. 612) this Court observed : "A review of the provisions of Chapter IV of the Act sufficiently discloses that the word "assessment" has been used in its widest connotation in that Chapter. The title of the chapter is "Deductions and Assessment". The section which deals with assessment merely as computation of income is S. 23, but several sections deal not with computation of income, but determination of liability, machinery for imposing liability and the procedure in that behalf. Section 18A deals with advance payment of tax and imposition of penalties for failure to carry out the provisions therein. Section 23A deals with power to assess individual members of certain companies on the income deemed to have been distributed as dividend. Section 23B deals with assessment in case of departure from taxable territories, Sec. 24B deals with collection of tax out of the estate of deceased persons, section 25deals with assessment in case of discontinued business. Section 25A with assessment after partition of Hindu undivided families and Sections 29, 31, 33 and 35 deal with the issue of demand notices and the filing of appeals and for reviewing assessment and section 34 deals with assessment of income which have escaped assessment. The expression "assessment" used in these sections is not used merely in the sense of computation of income and there is in our judgment no ground for holding that when by section 44, it is declared that the partners or members of the association shall be jointly and severally liable to assessment, it is only intended to declare the liability to computation of income under section 23 and not to the application of the procedure for declaration and imposition of tax liability and the machinery for enforcement thereof." In Commr. of Income-tax v. Bhikaji Dadabhai and Co., (1961) 42 ITR 123 at p. 127 : (AIR 1961 SC 1265 at p. 1267) this Court quoted with approval the observations regarding the word "assessment" in 1961-41 ITR 425 : (AIR 1961 SC 609). In Commr. of Income-tax v. Patiala Cement Co. Ltd., (1957) 32 ITR 333 : (AIR 1957 SC 692) a similar question arose. The question was whether under Section 13 of the Finance Act, 1950, the appeals in respect of assessments for 1949-50 would be governed by the Patiala Income Taxt Act, 2001 or by the Indian Income-tax Act. We may here setout Section 13 of the Finance Act, 1950: "If immediately before the 1st day of April, 1950, there is in force in any Part B State other than Jammu and Kashmir or Manipur, Tripura or Vindhya Pradesh or in the merged territory of Cooch-Behar any law relating to income-tax or super-tax or tax on profits of business, that law shall cease to have effect except for the purposes of the levy, assessment and collection of income-tax and super-tax in respect of any period not included in the previous year for the purposes of assessment under the Indian Income-tax Act, 1922 (11 of 1922) for the year ending on 31st day of March, 1951, or for any subsequent year, or, as the case may be, the levy, assessment and collection of the tax on profits of business for any chargeable accounting period ending on or before the 31st day of March, 1949." This Court held that it is the provision of the Patiala Act 2001 that applied. No point was raised that in any event the Patiala Act having ceased to have effect, the provisions dealing with appeals were not concerned with the levy, assessment and collection of income-tax. In Bhailal Amikn and Sons Ltd. v. R.P. Dalal, (1953) 24 ITR 229 : (AIR 1953 Bom 441) the Bombay High Court (Chagla, C.J., and Shah,J.), interpreting section 7 of the Taxation Laws (Extension to Merged States and Amendment) Act (67 of 1949) the relevant portion of which is in the following terms : "7. (1) If, immediately before the 26th day of August 1949, there was in force in any of the merged States any law relating to income-tax, super-tax, or business profits tax, that law shall cease to have effect except for the purposes of the levy, assessment and collection of income-tax, and super tax in respect of any period not included in the previous year for the purposes of assessment under the Indian Income-tax Act, 1922, as extended to that State by Section 3, or, as the case may be, the levy, assessment and collection of business profits tax for any chargeable accounting period ending on or before the 31st day of March 1948, and for any purposes connected with such levy, assessment or collection…………." Observed : "It is urged by Mr. Palkhiwalla for the petitioner that the words "levy, assessment and collection" do not include a right of appeal against the assessment order and the Baroda law did not continue to apply to any rights of appeal that the petitioners might have had in respect of the order of assessment. In the first instance this argument appears to me to be a perfectly futile argument, because, if I were induced to take such a view of the section it would leave the petitioners without any right of appeal at all. If the Baroda Act ceases to apply and obviously the Indian Act does not apply to the assessments of accounting years prior to the accounting year 1948-49, there is no right of appeal, and the petitioners could not have gone to the Tribunal at all, for there is no other section or sections which confer any right of appeal under the Indian Income-tax Act, in respect of assessments made under the Baroda Act. But, apart from this, in my opinion the words "for the purpose of levy, assessment and collection of income tax" include all procedure for the levy, assessment and collection of income tax for without the procedure there can be no levy, assessment or collection; and taking in particular "assessment" with which we are concerned on this petition the assessment is not final until all remedies by way of Appeal which are given by the Act are exhausted. This view is emphasized by the concluding words of sub-section(1) which are "for any purposes in connection with such levy, assessment and collection." There can in any event be no doubt that the procedure for assessment including rights of appeal are included in the words "purpose connected with assessment". In my opinion, therefore, the true construction of sub-section (1) of section 7 is that the Baroda Act continues to apply to the assessments of the petitioners even as regards the right of appeal which was given under the Act to the Huzur Adalat." It is quite clear from the authorities cited above that the word "assessment" can bear a very comprehensive meaning; it can comprehend the whole procedure for ascertaining and imposing liability upon the tax payer. (Kalawati Devi v . I.T. Commr., W.B., AIR 1968 SC 162 (167)