Appealable assessment order principle upheld where refusal of deductions and rebate formed part of the assessment itself.

An assessment order that includes refusal of claimed deductions and rebate is appealable in appellate review, because the denial forms part of the assessment process itself. The challenge before the Commercial Tax Officer and the further proceeding before the Appellate Tribunal were directed against the assessment order, so the Tribunal had jurisdiction to entertain the appeal. The maintainability objection failed because it was not raised before the lower authorities and, in any event, lacked substance. The revision was dismissed, leaving the Tribunal's order undisturbed and requiring effect to be given to the assessee's claims.

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Issues: Whether the appeal to the Appellate Tribunal against the assessment order was competent where the assessing officer had refused deductions and rebate.

Analysis: The refusal to grant the claimed deductions and rebate formed part of the assessment process and the appeal before the Commercial Tax Officer, followed by the further proceeding that reached the Appellate Tribunal, was directed against the assessment order itself. The objection to maintainability was not taken before the lower authorities and, in any event, had no substance.

Conclusion: The appeal to the Appellate Tribunal was competent, and the objection to its maintainability failed.

Final Conclusion: The dismissal of the revision left the Tribunal's order undisturbed and required full effect to be given to the assessee's claims.

Ratio Decidendi: An order finalising assessment, which includes refusal of claimed deductions or rebate, is an appealable assessment order for purposes of appellate review.

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