https://www.taxtmi.com/caselaws?id=40251 The dominant issue was whether, in an assessment under s.147 of the Income-tax Act, 1961 pursuant to a return filed on notice under s.148, the Assessing Officer can levy interest for default in filing the return under s.139(8). The SC held that an initial assessment made under s.147 (where no earlier assessment existed) is a "regular assessment" for purposes of s.139(8), and the statutory scheme and purpose of interest provisions require imposing interest to avoid an absurd result whereby a non-filer would escape liability compared to a late filer; accordingly, interest under s.139(8) is chargeable in such proceedings. The SC further held that Explanation 2 to s.139(8) is clarificatory and applies to the relevant assessment year. The appeal was dismissed with costs. en-us Fri, 01 Dec 2000 00:00:00 +0530 Mon, 05 Jan 2026 15:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=40251 The dominant issue was whether, in an assessment under s.147 of the Income-tax Act, 1961 pursuant to a return filed on notice under s.148, the Assessing Officer can levy interest for default in filing the return under s.139(8). The SC held that an initial assessment made under s.147 (where no earlier assessment existed) is a "regular assessment" for purposes of s.139(8), and the statutory scheme and purpose of interest provisions require imposing interest to avoid an absurd result whereby a non-filer would escape liability compared to a late filer; accordingly, interest under s.139(8) is chargeable in such proceedings. The SC further held that Explanation 2 to s.139(8) is clarificatory and applies to the relevant assessment year. The appeal was dismissed with costs. Case-Laws Income Tax Fri, 01 Dec 2000 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=40251