Appealability under Agricultural Income-tax law depends on a statutory assessment order, not a procedural principal-officer notice.

Section 31 of the Agricultural Income-tax Act, 1950 permits an appeal only against an assessment order or another order expressly covered by the section, including a denial of liability to be assessed. A notice or order treating a person as the principal officer under section 25(3) and section 2(p)(ii) is only procedural and does not create a separate appealable adjudication. On that basis, an appeal at the pre-assessment stage against the principal-officer notice/order was held not maintainable, and the assessee could not challenge liability through section 31 at that point.

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Issues: Whether an order treating a person as the principal officer of a company under the Agricultural Income-tax Act, 1950, was appealable under section 31, and whether a person denying liability to be assessed could appeal against such an order before an assessment was made.

Analysis: Section 31 permits an appeal by an assessee objecting to the amount assessed, tax determined, loss computed, or denying liability to be assessed, but such denial must be raised against an assessment order or against an order specifically falling under one of the enumerated provisions in the section. The order in question was neither an order under section 25 nor an order under section 2(p)(ii). Section 25(3) is only a procedural provision authorising notice to the principal officer in the course of assessment, and section 2(p)(ii) merely defines who may be treated as principal officer after notice. Neither provision confers a separate adjudicatory order capable of appeal under section 31.

Conclusion: The appeal before the Assistant Commissioner was not maintainable, and the assessee could not challenge the principal-officer notice/order at that stage. The questions referred were answered in the affirmative, against the assessee and in favour of the department.

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