Section 172 assessment procedures are examined where a shipping...

Section 172 assessment procedures are examined where a shipping assessee elected annual assessment of total income under Section 172(7), while separate vessel-wise assessments were also made under Section 172(4). The notes identify the contention that, after exercising the annual-assessment option, separate assessments for individual vessels should not proceed. They also record that a return processed under Section 143(1), resulting in a refund, had become final. The High Court found the issues arguable and granted interim protection by staying recovery under the Section 172(4) assessments pending final disposal of the writ petition.