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Issues:
1. Interpretation of appealable orders under the Agricultural Income-tax Act. 2. Denial of liability to be assessed under the Act and its impact on appeal rights. Analysis: The judgment pertains to a reference made by the Kerala Agricultural Income-tax Appellate Tribunal regarding the appealability of an order under the Agricultural Income-tax Act. The Tribunal held that the order in question was not appealable as it was not passed under specific sections of the Act. The assessee, a director of a company, was proposed to be treated as the principal officer for assessment purposes. The assessing authority's order was challenged before the AAC and subsequently before the Tribunal. The Tribunal concluded that the order did not fall under appealable categories and dismissed the appeal, suggesting the assessee could challenge her liability upon assessment. The High Court analyzed the provisions of Section 31 of the Act, emphasizing that an appeal can be filed by an assessee who denies liability to be assessed against the order of assessment or certain specified orders. The Court clarified that for appeals not against assessment orders, the order challenged must fall under specific sections of the Act. The Court examined whether the order could be considered under Section 25, determining that it was a procedural provision for issuing notices and not for adjudication of liability. Regarding the Tribunal's view that the order was made under Section 2(p)(ii) defining the principal officer, the Court disagreed, stating it did not involve passing an order. However, the Court reiterated that for an appeal to be maintainable, the order must fall under the enumerated sections for appealability. Ultimately, the Court answered the referred questions in favor of the department, holding against the assessee. The judgment highlights the importance of the correct interpretation of appealable orders under the Agricultural Income-tax Act and the impact of denial of liability on appeal rights.
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