Carried-forward agricultural loss must be given effect by revising later assessment despite prior completion.

Section 14 of the Coorg Agricultural Income-tax Act, 1951 confers a statutory right to carry forward a loss in agricultural income and set it off against the following year's income, and requires the assessing authority to give effect to that adjustment. An earlier completion of the 1953-54 assessment did not justify refusal to revise it after the 1952-53 loss was finally determined and directed to be carried forward. The refusal to revise was inconsistent with the statutory scheme because it denied the assessee the benefit of the carried-forward loss, and the assessment had to be revised accordingly.

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Issues: Whether the assessing authority was bound to revise the assessment for 1953-54 so as to give effect to the carried-forward loss determined for 1952-53 under section 14 of the Coorg Agricultural Income-tax Act, 1951.

Analysis: Section 14 confers on the assessee a statutory right to have a loss in agricultural income carried forward and set off against the income of the following year, and casts a corresponding duty on the assessing authority to give effect to that result. The fact that the assessment for 1953-54 had earlier been completed did not justify refusal to revise it once the loss for 1952-53 had been finally determined and directed to be carried forward. The administrative refusal to revise the assessment was therefore inconsistent with the statutory scheme and denied the assessee the benefit of the earlier decision.

Conclusion: The assessing authority was bound to revise the assessment for 1953-54 and to give effect to the order carrying forward the loss; the writ was issued in favour of the petitioner.

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