Power to amend assessment lists at any time includes escaped property tax corrections for past years under municipal law.

Section 67 of the Punjab Municipal Act, 1911 was construed as conferring a broad power to amend an assessment list "at any time", including after the list had become final and after the relevant year had expired. Read with section 66, the scheme allowed later correction of omissions caused by fraud, accident or mistake, and the amendment could operate on the assessment years to which the list related. The later insertion of section 68A, which expressly limited the operation of amendments for erroneous included valuations, confirmed that section 67 carried no such temporal restriction. The Municipal Committee could therefore amend earlier lists and bring escaped property to tax for past years.

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Issues: Whether section 67 of the Punjab Municipal Act, 1911 empowered the Municipal Committee to amend an assessment list at any time so as to include property that had escaped assessment, and whether such amendment could operate on prior assessment years.

Analysis: Section 67 conferred a wide power to amend an assessment list "at any time" and the expression was not confined to the period before the list became final or before the year of operation expired. Read with section 66, the statutory scheme showed that an authenticated assessment list was subject to such later amendments as were duly made. The purpose of the provision was to enable correction where property or tax liability had been omitted through fraud, accident or mistake, and the omission might come to light long after the list had been brought into force. Section 68A, introduced later, dealt only with erroneous valuation or assessment already included in the list and, unlike section 67, expressly limited the time from which the amendment would operate. That contrast confirmed that section 67 carried no such limitation. The amendment, once made, cured the defect in the list for the year or years to which that list related.

Conclusion: The Municipal Committee had authority under section 67 to amend the earlier assessment lists and to assess the escaped property for the relevant past years.

Ratio Decidendi: A statutory power to amend an assessment list "at any time" includes the power to correct escaped assessment after the list has become final and after the relevant year has passed, unless the statute itself imposes a contrary limitation.

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