S. SANKAPPA AND OTHERS vs THE INCOME-TAX OFFICER, CENTRAL CIRCLE II,BANGALORE

The Supreme Court held that proceedings for rectification under Section 35(5) of the Income Tax Act, 1922, are indeed proceedings for assessment as per Section 297(2)(a) of the Income Tax Act, 1961. The Court clarified that the term 'assessment' encompasses all proceedings from filing returns to determining tax payable. Consequently, the Income Tax Officer's actions to rectify the assessments of the appellants were valid, and the appeal was dismissed.