https://www.taxtmi.com/caselaws?id=37014 In reassessment proceedings under section 148 for assessment years governed by the Indian Income-tax Act, 1922, interest under the proviso to section 139(1) of the Income-tax Act, 1961 was not chargeable. Section 297 was construed as carrying only the machinery of the new Act into reopened assessments, not as creating a fresh substantive liability for earlier years. Because the returns related to periods before 1 April 1962, the interest provision was treated as a new burden and could not be applied retrospectively. The levy therefore failed. en-us Mon, 07 Aug 1978 00:00:00 +0530 Fri, 26 Mar 2010 10:20:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=37014 In reassessment proceedings under section 148 for assessment years governed by the Indian Income-tax Act, 1922, interest under the proviso to section 139(1) of the Income-tax Act, 1961 was not chargeable. Section 297 was construed as carrying only the machinery of the new Act into reopened assessments, not as creating a fresh substantive liability for earlier years. Because the returns related to periods before 1 April 1962, the interest provision was treated as a new burden and could not be applied retrospectively. The levy therefore failed. Case-Laws Income Tax Mon, 07 Aug 1978 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=37014