https://www.taxtmi.com/caselaws?id=261121 Reassessment under sections 147 and 148 was treated as valid where the original section 143(3) assessment did not show that the interest claim had been examined or any opinion formed on that issue, and the recorded reasons disclosed escapement of income based on relevant material. The assessee's change-of-opinion plea failed because the earlier order did not reflect application of mind to the point reopened. On the merits, proportionate interest was disallowed under section 36(1)(iii) because the assessee did not adequately prove that borrowed funds were used for business purposes, while interest-free advances and investments lacked sufficient nexus and commercial expediency. The reassessment and the disallowance were both upheld. en-us Thu, 25 Jun 2015 00:00:00 +0530 Fri, 03 Jul 2015 07:46:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=261121 Reassessment under sections 147 and 148 was treated as valid where the original section 143(3) assessment did not show that the interest claim had been examined or any opinion formed on that issue, and the recorded reasons disclosed escapement of income based on relevant material. The assessee's change-of-opinion plea failed because the earlier order did not reflect application of mind to the point reopened. On the merits, proportionate interest was disallowed under section 36(1)(iii) because the assessee did not adequately prove that borrowed funds were used for business purposes, while interest-free advances and investments lacked sufficient nexus and commercial expediency. The reassessment and the disallowance were both upheld. Case-Laws Income Tax Thu, 25 Jun 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=261121