Interest under section 139(8) was not leviable in reassessment under section 147(a) absent assessment under sections 143 or 144.

Interest under section 139(8) could not be imposed in reassessment proceedings initiated under section 147(a) where the assessment was not made under sections 143 or 144. The court applied the then-binding position that such interest was outside the statutory scope in those reassessment proceedings, so the levy was without jurisdiction and was quashed.

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Issues: Whether interest could be levied under section 139(8) of the Income-tax Act, 1961 in reassessment proceedings initiated under section 147(a) and notice issued under section 148.

Analysis: The assessment order showed that the Income-tax Officer had proceeded under section 147(a) and not under sections 143 or 144. The decision relied on the binding view that, in such reassessment proceedings as the law then stood, interest under section 139(8) could not validly be imposed.

Conclusion: The levy of interest was without jurisdiction and was quashed.

Ratio Decidendi: Interest under section 139(8) cannot be levied in reassessment proceedings initiated under section 147(a) when the assessment is not made under sections 143 or 144.

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