Interest under reassessment provisions remains leviable when first assessments are completed under section 147 read with section 143(3).

Interest under sections 139(8) and 217 of the Income-tax Act, 1961 was held leviable even where the assessment was completed for the first time under section 147 read with section 143(3). The court followed an earlier decision on the same point and applied that rule to reject the assessee's challenge. The result was that the levy of interest was upheld in favour of the revenue.

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Issues: Whether interest under section 139(8) and section 217 of the Income-tax Act, 1961, was leviable where the assessments for the assessment years 1979-80 and 1980-81 were completed for the first time under section 147 read with section 143(3).

Analysis: The question was covered by the earlier decision holding that interest under sections 139(8) and 217 is leviable even when the assessment is completed for the first time under section 147 read with section 143(3) of the Income-tax Act, 1961.

Conclusion: The question was answered against the assessee and in favour of the revenue.

Ratio Decidendi: Interest under sections 139(8) and 217 of the Income-tax Act, 1961 is leviable even where the assessment is completed for the first time under reassessment provisions under section 147 read with section 143(3).

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