Assessmen

After quoting the definition, Mahoney J.A. stated (p. 5629):

"That definitional section cannot, in my view, prevail to render the terms assessment and reassessment entirely interchangeable in a provision that clearly distinguishes between them and expressly provides differently in respect of them. In my opinion, subsection 152(4) is such a provision."

S.225.1(3), which was added applicable to "notices of assessment" mailed after 1984, did not apply where a reassessment was issued in 1983, and a notice of confirmation issued in 1984. Because a notice of confirmation does not effect any change to an assessment, it is not itself an assessment.