Enhancement of assessment requires increase in total assessable income, not merely an adjustment between income heads.

Under the appellate scheme, assessment means determination of the total income and tax payable, so a variation in one head of income does not by itself amount to an enhancement of the assessment. Where an appeal before the Assistant Commissioner results only in an internal adjustment between heads of income, without any increase in the total assessed income, no further appeal lies to the Commissioner under section 32(1). The right of further appeal arises only when the assessment as a whole, meaning the total assessable income, is enhanced.

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Issues: Whether, on an appeal before the Assistant Commissioner, an increase under one head of income without any increase in the total assessed income amounts to an enhancement of the assessment so as to permit a further appeal under section 32(1).

Analysis: The scheme of the Act treats assessment as the determination of the total income and the sum payable thereon. The provisions governing assessment and appeal indicate that what is appealed against is the assessment as a whole, not separate computations under different heads of income. An increase in one item of income, unaccompanied by an enhancement of the total assessment, does not amount to an enhancement of the assessment within the meaning of section 32(1). Since income-tax is one tax on the total assessable income, a variation in the constituent heads without increasing the overall assessment does not create a fresh right of appeal to the Commissioner.

Conclusion: No appeal lies to the Commissioner under section 32(1) in such a case.

Final Conclusion: The right of further appeal arises only where the assessment of total income is enhanced, and not where there is merely an adjustment between heads of income without enhancement of the overall assessment.

Ratio Decidendi: For the purposes of the appellate provisions, enhancement must be of the assessment as a whole, meaning the total assessable income, and not merely of an individual head of income.

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