https://www.taxtmi.com/caselaws?id=775962 The HC held that the assessment order, though incorrectly citing Section 147 alongside Section 143(3), was validly passed under Section 143(3), and the misquotation did not invalidate the proceedings under Section 292B. The reopening under Section 147 was not justified as the case was taken up for regular scrutiny with a valid notice under Section 143(2). The CIT(A)'s interpretation favoring Section 147 was erroneous, but the ITAT correctly treated the order as under Section 143(3). Regarding deduction under Section 80-IA, the court ruled against artificially segregating interest income from business income, affirming the assessee's entitlement to the full deduction. The interest income could not be offset against interest paid when it arose from the business. Both parties agreed this aligns with SC precedent favoring the assessee's claim for deduction without reduction. en-us Wed, 30 Jul 2025 00:00:00 +0530 Thu, 07 Aug 2025 16:11:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775962 The HC held that the assessment order, though incorrectly citing Section 147 alongside Section 143(3), was validly passed under Section 143(3), and the misquotation did not invalidate the proceedings under Section 292B. The reopening under Section 147 was not justified as the case was taken up for regular scrutiny with a valid notice under Section 143(2). The CIT(A)'s interpretation favoring Section 147 was erroneous, but the ITAT correctly treated the order as under Section 143(3). Regarding deduction under Section 80-IA, the court ruled against artificially segregating interest income from business income, affirming the assessee's entitlement to the full deduction. The interest income could not be offset against interest paid when it arose from the business. Both parties agreed this aligns with SC precedent favoring the assessee's claim for deduction without reduction. Case-Laws Income Tax Wed, 30 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775962