Reassessment Rejection Is Appealable: statutory appeal lies despite confirmation of the original assessment and available revision remedy.

Section 31 makes any order passed under section 14 appealable, so a rejection of an application for reassessment under section 14 is itself an appealable order even where the original best judgment assessment remains confirmed. The rejection cannot be treated as an order under section 12 merely because no reassessment follows. The availability of a revision remedy under section 33 does not bar the statutory appeal where section 31 expressly covers orders under section 14. The appellate authority's contrary view was therefore incorrect, and appealability under section 31 was affirmed.

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Issues: Whether an appeal lies under section 31 against an order rejecting an application for reassessment under section 14 and confirming the original best judgment assessment, and whether the availability of revision under section 33 bars such appeal.

Analysis: Section 31(1) makes any order passed under section 14 appealable to the Appellate Assistant Commissioner. An application for reassessment under section 14 may end either in reassessment or in rejection, and in either event the resulting order is one made under section 14. The rejection of the reassessment request cannot be treated as an order under section 12 merely because the original best judgment assessment is left undisturbed. The existence of a revisional remedy under section 33 does not exclude the statutory appeal where section 31 itself expressly covers orders passed under section 14.

Conclusion: An appeal was maintainable under section 31 against the order rejecting the reassessment application, and the contrary view of the appellate authority was incorrect.

Ratio Decidendi: Where the statute expressly makes orders passed under a reassessment provision appealable, rejection of a reassessment application is itself an appealable order under that provision, even if the original assessment remains confirmed.

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