This case had its genesis when Georgia Power Company (“Georgia Power”) filed a 2003 ad valorem tax return, including its estimate of its operating property’s fair market value, with the Commissioner of the State Board of Equalization. The State Commissioner reviewed and approved this valuation, apportioned it among the various counties in which Georgia Power owns such property, and proposed an assessment ratio. Pursuant to its power to make a “final assessment” under OCGA§ 48-2-18 (d), however, the Monroe County Board of Tax Assessors (“the Monroe Board”) rejected the State Commissioner’s fair market valuation and raised the assessment ratio. Georgia Power then brought this action for equitable relief, and the trial court granted summary judgment to the Monroe Board. Because we find that the term “final assessment” does not include a revaluation of the fair market value of a public utility’s property, we reverse.
On appeal from a grant of a motion for summary judgment, we review the evidence de novo, viewing it in the light most favorable to the nonmovant, to determine whether a genuine issue of fact remains and whether the moving party is entitled to judgment as a matter of law. Rubin v. Cello Corp., 235 Ga. App. 250 (510 SE2d 541) (1998).
The relevant facts are not in dispute. In compliance with its duty under OCGA § 48-5-511 (b) to provide a sworn statement of “a just, true, and full return of the fair market value of [its] property,” Georgia Power filed a 2003 property tax return with the State Board showing that its operating property had a fair market value of almost $8.8 billion. The State Board reviewed this value and then apportioned it among the 156 counties in which Georgia Power had operating properties, with Monroe County’s portion amounting to nearly $229 million. Applying the 36.27 percent assessment ratio taken from the state auditor’s annual Sales-Assessment Ratio Study, the State Commissioner eventually certified to the Monroe Board that Georgia Power’s property in that county had been assessed at $83 million.
On the basis of its consultant’s report, however, the Monroe Board raised the fair market value of Georgia Power’s Monroe County property from $229 million to $701 million, and also raised the assessment ratio to 40 percent.1 As a result, Monroe County assessed the value of Georgia Power’s property at $280 million, more than three times that assessed by the State Commissioner. The *708Monroe Board then issued 2003 tax bills to Georgia Power totaling $5.98 minion, as opposed to the less than $2 million that would have been owed under either a 36 percent or a 40 percent ratio at the State Commissioner’s appraised value.
Georgia Power objected on the ground that even if counties had the power to raise assessment ratios, county boards are not empowered to change the State Commissioner’s determination of fair market value, which would undermine the widely accepted practice of assessing utility properties as a whole at the state level. Georgia Power then brought this action seeking to bar the Monroe Board from substituting its own fair market value for the State Commissioner’s in the course of making its “final assessment.” Both parties moved for summary judgment, which the trial court granted to the Monroe Board.
The Monroe Board asserts that it has the authority to reset not only the assessment ratio imposed on Georgia Power’s Monroe County property, but also the fair market value of that property as appraised by the State Commissioner. In support of this assertion, the Monroe Board cites OCGA§ 48-2-18 (d), which provides that “[wjithin 30 days after receipt of the [State Commissioner’s] proposed digest of assessments, the county board of tax assessors shall make the final assessment of the property in question and provide notice to the taxpayer.” (Emphasis supplied.) We disagree.
As we have already noted, the process of taxation of a public utility begins when the utility files a sworn statement of its property’s value with the State Board. Under OCGA § 48-2-18 (b), and upon the completion of a “digest of assessments proposed by the [State Commissioner,” the State Board
shall carefully examine the proposed assessments of each class of taxpayers or property and the digest of proposed assessments as a whole to determine that they are reasonably apportioned among the several tax jurisdictions and reasonably uniform with the values set on other classes of property throughout the state.
OCGA § 48-5-511 (c) provides that in the course of “promulgating the regulations specifying the method of apportionment” concerning the taxation of public utilities, the State Commissioner shall consider factors including those which “in [his] judgment are reasonably calculated to apportion fairly and equitably the property between the various tax jurisdictions.”
In the course of construing the procedural provisions of OCGA § 48-2-18, our Supreme Court noted in Telecom*USA v. Collins, 260 *709Ga. 362 (393 SE2d 235) (1990) that “neither the method for establishing the ‘final assessment’ nor any possible limitations on the counties’ power to modify the Commissioner’s ‘proposed assessment’ are squarely raised in this case,” and declined to reach the issue as a result. Id. at 366, n. 3. This is precisely the question before us today, however: whether the Monroe Board exceeded its authority when, in the course of making the “final assessment” of Georgia Power’s property, it substituted not only its own assessment ratio but also its own fair market value for those calculated by the State Commissioner.
We begin our analysis with the “golden rule” of statutory construction, which requires us to follow the literal language of the statute unless it produces contradiction, absurdity or such an inconvenience as to insure that the legislature meant something else. When literal reading of the statute produces such an absurdity, the appellate court must then seek to make sense out of the statute, while being faithful to the legislative intent. To define the legislative intent, the court considers the purpose of the statute and its impact on the body of law as a whole. The court also considers the law as it existed before the statute was passed and identifies the mischief sought to be corrected. Finally, when a taxing statute has doubtful meaning, it must be construed liberally in favor of the taxpayer and against the State.
(Citations and punctuation omitted.) Telecom*USA, supra at 363-364 (1).
Monroe County argues that if the General Assembly had desired to grant to county boards only the power to adjust assessment ratios, it could have done so, as when it defined the term in 1988 amendments concerning the examination of county tax digests. See OCGA § 48-5-341 (3). The term “assessment” itself is defined nowhere in the Revenue Code, however, and is generally defined as either the appraisal of value or the assessment of tax. See Black’s Law Dictionary, 5th ed., 1979 (defining “assessment” as “[t]he listing and valuation of property for the purpose of apportioning a tax upon it,” and “[a]lso determining the share of a tax to be paid by each of many persons[,] or apportioning the entire tax to be levied among the different taxable persons, establishing the proportion due from each”) (emphasis supplied). We therefore turn to other statutes “relating to the same subject matter,” construing them “together to ascertain the legislative intent.” Schrenko v. DeKalb County School Dist., 276 Ga. 786, 790 (1) (582 SE2d 109) (2003).
*710In the ordinary course, county boards will have the power both to appraise value and to assess tax. See OCGA§ 48-5-305 (b) (conferring on the county board the “full power and authority necessary’ to assess “the fair market value of all property in the county’). In such cases, there is little reason to distinguish between the two procedures. See Rogers v. DeKalb County Bd. of Tax Assessors, 247 Ga. 726 (279 SE2d 223) (1981) (county board may determine fair market value of airplane by reference to either “blue book” value or depreciated value). We have also held that a county board cannot be compelled to devote its own resources to a new and independent determination of the value of a public utility’s property. See Burt, Burt & Rentz Retirement Pension Trust v. Dougherty County Tax Assessors, 256 Ga. App. 648, 650-652 (2) (a), (b) (569 SE2d 557) (2002).
It does not follow, however, that a county board’s power to make a “final assessment” includes that of reassessing “fair market value” as to taxpayers who must file returns with the State Commissioner. The very statute on which the Monroe Board relies, OCGA§ 48-5-341 (3), provides that “ ‘[assessment ratio’ means the fractional relationship the assessed value of property bears to the fair market value of the property’ — suggesting that the act of assessment is neither more nor less than the application of a ratio to a given fair market value. Likewise, when it sets out the various duties of the county boards of tax assessors, OCGA§ 48-5-263 (b) indicates that the appraisal of fair market value is only the first step in a lengthy process of assessment:
Each member of the county property appraisal staff shall: (1) [mfake appraisals of the fair market value of all taxable property in the county other than property returned directly to the commissioner,... (3) [pfrepare annual assessments on all taxable property appraised in the county and submit the assessments for approval to the county board of tax assessors; . . . [and] (6) [a]ttend hearings of the county board of equalization and provide information to the board regarding the valuation and assessments approved by the county board of tax assessors. .. .
(Emphasis supplied.) Finally, and most important, that part of the Revenue Code concerning the powers of county boards specifies that “fnjothing contained in this part shall apply to those persons who are required to make their returns to the [Cfommissioner.” (Emphasis supplied.) OCGA§ 48-5-313; see also Pullman Co. v. Suttles, 187 Ga. 217, 222-223 (5), (6) (199 SE 821) (1938) (a county board’s assertion of its powers over a railroad required to make tax returns to the State deprived the railroad of due process of law).
*711We conclude that because a county board’s “final assessment” under OCGA § 48-2-18 cannot include a reappraisal of the fair market value of any taxpayer, including a public utility, required to make a return to the State, the trial court erred when it denied Georgia Power’s motion for summary judgment. We therefore reverse the judgment of the trial court and remand the case with direction to issue an injunction barring the Monroe Board from collecting taxes on Georgia Power’s Monroe County property based on the Monroe Board’s reappraisal of that property’s fair market value.
Judgment reversed and case remanded with direction.
Johnson, P. J., Miller, Ellington and Mikell, JJ., concur. Adams, J., concurs specially. Barnes, C. J., dissents.See OCGA § 48-5-7 (a) (“Except as otherwise provided in this Code section, taxable tangible property shall be assessed at 40 percent of its fair market value.”).