Reassessment under section 148 is not regular assessment; interest under section 217 is not chargeable on that basis.

Proceedings initiated under section 148 culminate in reassessment, not regular assessment, and the term "regular assessment" in section 217 is confined to assessments under sections 143 and 144. An assessment first framed under sections 147/148 may be an assessment in a broad sense, but it does not fall within section 2(40) for fastening interest liability under section 217. Accordingly, interest under section 217 is not chargeable on an assessment made in pursuance of notice under section 148.

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Issues: Whether an assessment made for the first time under section 143(3) of the Income-tax Act, 1961, in pursuance of notice under section 148 amounts to a reassessment and not a regular assessment, so that interest under section 217 is not chargeable.

Analysis: Proceedings initiated under section 148 culminate in reassessment. The term "regular assessment" in section 217 has a restricted meaning and covers assessments under sections 143 and 144 only. An assessment framed under sections 147/148, though an assessment in a broad sense, is not a regular assessment within section 2(40) for the purpose of fastening interest liability under section 217.

Conclusion: The assessment completed in pursuance of notice under section 148 was a reassessment and not a regular assessment, and interest under section 217 was not chargeable.

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