'Subbappa's case, (E)', appears to be an authority for the proposition that alterations made in an assessment list under Section 81(3) have limited retrospective operation i.e. the liability for a rate under an assessment list which is finalised and authenticated during the course of an official year arises in case of inadvertent omissions as from the date 011 which the assessment list is brought into operation and in cases where there has been new construction or alteration of a building during the course of the year from the date on which the building became liable to tax.
But 'Subbappa's case', (E), in our judgment, is no authority for the proposition that a more extensive retrospective operation to an assessment list is intended to be given so as to enable a Municipality to alter the assessment list of previous years. In other words, the assessment list for each year comes to an end on the expiry of the official year and a fresh assessment list comes into existence as from the 1st date of the official year, and the assessment list of the previous year cannot be amended so as to impose fresh liability after the close of the official year.
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