https://www.taxtmi.com/caselaws?id=769825 ITAT Pune held that reassessment notices under section 148 issued for assessment years 2014-15 and 2016-17 were barred by limitation, following SC precedents in Ashish Agarwal and Rajeev Bansal cases. The notices were issued beyond the surviving time limit available under the new regime. On merits, the tribunal allowed interest deduction under section 36(1)(iii) as the borrowed funds were used for business purposes. ICDS IX provisions were held inapplicable to AY 2014-15 as they were introduced from AY 2016-17. Interest being a period cost must be allowed in the year incurred, not apportioned to work-in-progress. Revenue appeal dismissed. en-us Mon, 10 Mar 2025 00:00:00 +0530 Fri, 02 May 2025 08:54:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=769825 ITAT Pune held that reassessment notices under section 148 issued for assessment years 2014-15 and 2016-17 were barred by limitation, following SC precedents in Ashish Agarwal and Rajeev Bansal cases. The notices were issued beyond the surviving time limit available under the new regime. On merits, the tribunal allowed interest deduction under section 36(1)(iii) as the borrowed funds were used for business purposes. ICDS IX provisions were held inapplicable to AY 2014-15 as they were introduced from AY 2016-17. Interest being a period cost must be allowed in the year incurred, not apportioned to work-in-progress. Revenue appeal dismissed. Case-Laws Income Tax Mon, 10 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=769825