In the course of finding that the exercise by the Minister of his discretion to disallow an expense was an assessment that could be appealed as such, Thorson P. stated (at p. 857):
The assessment is different from the notice of assessment; the one is an operation, the other a piece of paper. The nature of the assessment operation was clearly stated ... in Federal Commissioner of Taxation v. Clarke ((1927) 40 C.L.R. 246 at 277):
An assessment is only the ascertainment and fixation of liability. …
The purpose of providing an appeal from the assessment is to ensure to the taxpayer that it shall be correct in fact and in law. …
[C]ertainly it should not be assumed, without most explicit terms, that Parliament intended that the administration and definition of a policy, which it had left to the discretion of a Minister responsible to it, should be left to the discretion of the Court, which is in no way responsible to it.