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"Additional Commissioner means a person 35 appointed to be an Additional Commissioner of Ihcome Tax Under subsection (1) of section 117."

Thus, combined reading of all the above sections makes it clear that prior to amendment mode by Finance Act, 2 0 0 7 , t h e legislature treated 'Additional Commissioner' and 'Joint Commissioner' differently for the purposes of performing the role as M/s. Tata Communications Ltd., (Formerly Videsh Sanchar Nigam Ltd.,) an Assessing Officer, despite the fact that for all the other purposes 'Joint Commissioner' meant Additional Commissioner as well., as per section 2(25C). It is clear from the facts that by way of subsequent amendment by Finance Ad, 2007 , words 'Additional Commissioner' have also been inserted along with words 'Joint commissioner', in section 2(7A) which defines the term for 'Assessment Officer' In case, the legislature would have intended and meant that for the purpose of acting as Assessing Officer, 'Joint Commissioner' and 'Additional Commissioner' means one and the same, then there was no need to come out with an amendment made by Finance Act, 2007, wherein the word 'Additional Commissioner' was also inserted in the definition of 'Assessing Officer' as contained in section 2(7A). Thus, it is clear as per the plain reading of the statute that when the assessment order was passed, the 'Additional Commissioner was not authorized to act as Assessing Officer.