https://www.taxtmi.com/caselaws?id=5108 The expression "any person who has not hitherto been assessed" in section 18A(3) of the Income-tax Act, 1922 was understood to include a person provisionally assessed under section 23B. The analysis treats "assessed" as an unqualified term covering both provisional and regular assessment unless the statute expressly narrows it. The scheme of section 18A distinguishes provisional and regular assessments where intended, including references in later sub-sections, which supports the broader reading. Later provisions of the Income-tax Act, 1961 do not control the meaning of the earlier provision. en-us Tue, 20 Aug 1968 00:00:00 +0530 Tue, 03 Feb 2015 12:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=5108 The expression "any person who has not hitherto been assessed" in section 18A(3) of the Income-tax Act, 1922 was understood to include a person provisionally assessed under section 23B. The analysis treats "assessed" as an unqualified term covering both provisional and regular assessment unless the statute expressly narrows it. The scheme of section 18A distinguishes provisional and regular assessments where intended, including references in later sub-sections, which supports the broader reading. Later provisions of the Income-tax Act, 1961 do not control the meaning of the earlier provision. Case-Laws Income Tax Tue, 20 Aug 1968 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=5108