Revised return does not trigger a second provisional assessment; revised particulars belong in final assessment proceedings.

A revised return filed after a provisional assessment under section 18 of the Agricultural Income-tax Act does not, by itself, require or authorise a fresh provisional assessment. Section 16 permits a revised return before final assessment, but it does not cancel the original return or compel repeated provisional orders. The revised particulars are to be considered at the stage of final assessment, while section 18 operates only as an advance estimate. The Madras Agricultural Income-tax Rules, including the special provisional basis for tea income, do not support a second provisional assessment merely because revised figures are filed.

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Issues: Whether, after a provisional assessment has been made under section 18 of the Agricultural Income-tax Act on the basis of the original return, the filing of a revised return under section 16(3) entitles the assessee to a fresh provisional assessment.

Analysis: Section 16 regulates returns and permits a revised return before final assessment, but it does not nullify the original return or require repeated provisional assessments. Section 18 authorises only a provisional assessment as an advance of the regular assessment, and the second proviso to rule 7 of the Madras Agricultural Income-tax Rules merely provides a special provisional basis for tea income, with the assessment remaining subject to revision when the Indian income-tax assessment is determined. The scheme of the provisions shows that the revised particulars are to be taken into account in the final assessment, not in a second provisional assessment. The wording of the rule does not support the view that every revised return must trigger a further provisional order.

Conclusion: The assessee was not entitled to a fresh provisional assessment on the revised return. The revised return was to be considered at the stage of final assessment, and the refusal to make another provisional order was upheld.

Ratio Decidendi: Once a provisional assessment has been made on the basis of a return, a revised return filed before final assessment does not require or authorise a further provisional assessment; the revised particulars are to be considered in the final assessment proceedings.

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