Summary assessment beyond permitted adjustments is appealable when it alters status or tax liability unlawfully.

An order described as a summary assessment under section 143(1) remains appealable under section 246(c) when the assessing authority goes beyond the limited adjustments permitted by that provision and alters the assessee's status or tax liability without statutory authorisation. The objection procedure under section 143(2)(a) is not the exclusive remedy in such a case, because it presupposes a valid summary assessment within section 143(1). Where the order exceeds the confines of the summary scheme, it is not treated as a true section 143(1) assessment and may be challenged by appeal.

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Issues: Whether an assessment purportedly made under section 143(1) of the Income-tax Act, 1961, which altered the assessee's status and computed tax contrary to the assessee's claim under sections 161 and 166, was appealable under section 246(c), and whether the assessee was bound instead to pursue the objection procedure under section 143(2)(a).

Analysis: Section 143(1) permits only limited adjustments while processing a return without requiring the assessee's presence or evidence. Where the Income-tax Officer goes beyond those limited adjustments and makes changes not contemplated by the provision, the order is not truly an assessment within the limited summary scheme. In such a case, the objection procedure under section 143(2)(a) is not the only remedy, because that procedure presupposes a valid assessment under section 143(1). An order that exceeds the statutory limits and changes the assessee's status and tax liability on a basis not authorised by the summary provision is therefore amenable to appeal under section 246(c).

Conclusion: The appeal before the first appellate authority was maintainable, and the assessee was entitled to challenge the order by appeal rather than being confined to the objection mechanism under section 143(2)(a).

Ratio Decidendi: An order styled as a summary assessment under section 143(1) is appealable when the assessing authority travels beyond the limited adjustments authorised by that provision, because such an order is not an assessment made within the statutory confines of section 143(1).

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