Completion of income tax assessment within the limitation period remains valid even if terms were not communicated, remedies preserved.

Whether an income tax assessment is valid where the assessing officer completes assessment within the statutory four year limitation despite failure to communicate the assessment terms: the note clarifies that completion of assessment by the officer within the prescribed limitation is a valid procedural act and is not rendered invalid by non communication of the terms within that period; the statutory scheme preserves the assessee's remedies under other provisions to challenge or seek relief against the assessment, so the assessment stands though grievance procedures remain available to the assessee.

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Issues: Whether an income-tax assessment can be completed by the Income-tax Officer within the four-year limitation period even though the terms of the assessment order were not communicated to the assessee within that period.

Analysis: The question arises under Section 66(1) of the Income-tax Act, 1922. The issue concerns whether the procedural act of completing the assessment and determining tax payable can be validly performed by the Income-tax Officer within the statutory four-year period despite non-communication of the assessment terms to the assessee during that period, and whether the assessee's remedies for grievance against such an assessment are preserved by other provisions of the Act. The reasoning focuses on the distinction between completion of assessment as an act by the officer within the limitation period and subsequent communication to the assessee, and on the statutory scheme that provides for the assessee's rights to challenge or seek relief against the assessment by other specified provisions.

Conclusion: The question is answered in the affirmative and against the assessee; an assessment may be completed by the Income-tax Officer within the four-year limitation period even if the terms of the assessment were not communicated to the assessee within that period.

Ratio Decidendi: Where a statute prescribes a limitation for completion of assessment, the mechanical completion of assessment by the assessing officer within that period is valid notwithstanding subsequent non-communication of the assessment terms, and the statutory scheme that provides remedies to the assessee operates to protect the assessee's rights.

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