The above dictum of the Privy Council was quoted with approval by this Court in C: A. Abraham v. Income-tax Officer, Kottayam ap.d another(!). In Sankappa's case (supra) the same Bench which had decided the Parikh's case and delivered the judgment through Shah, J. as he then was, speaking thro-ugh Bhargava, J. followed Abraham's case (supra) and the decision of this Court in Kalawati Devi Harlalka v. Commissioner of Income-tax(") wherein it has been stated that the word "assessment" is capable of bearing a very comprehensive meaning; in the context it can comprehend the whole procedure for ascertaining and imposing· liability on the tax payer. It is to be . noticed that the marginal note of section 23 is· "Assessment" and sub-section ( 3) says "the Income-tax Officer.: ...... shall, by an order in writing, assess the total income of the assessee"· and then adds '.'determine the sum payable by him on the basis of such assessment." · Literally speaking, therefore, the assessment is of the total income of the assessee and then in the same order the sum payable by the assessee is determined which would include income-tax, surcharge, super-tax etc. Under section 24 of the Act, loss is computed and is allowed to be set off against the income of the same year or carried forward to the next year. . If one were to go upon the use of the literal words, then section 24 is for computation of the loss. Yet it is a step in the assessment proceeding and will form part of the order of assessment itself. Section 23A as the marginal note indicates is the "Power to assess Companies fo super-tax. on undistributed income in certain cases". The relevant words of sub-section (1) of section 23A are the following : "Where the Income-tax Officer is satisfied ........ the Income-tax Officer shall unless he is satisfied .. make an order in writing that the company shall, apart from the sum determined as payable by it on the basis of the assessment under section 23, be liable to pay super-tax" at the rates specified "on the undistributed balance of the total income of the previous year ...... " It would thus be seen that although -in a narrow sense an order under section 23A may not be called an order of assessment, surely it is a part of the assessment proceeding and may be called a supplementary assessment order directing a company to pay additional amount of super-tax on the undistributed balance of the total income as assessed and determined in accordance with the provisions of section 23. We shall now read section 35 (1) :
