https://www.taxtmi.com/caselaws?id=788907 Reopening under section 148 based on a revenue audit objection was held invalid where the original section 143(3) assessment had already examined the same loans and advances, and no new tangible material existed; the reassessment was therefore a mere change of opinion and the notice was quashed. On the interest issue, the assessee showed that its own capital, reserves and other interest-free funds were sufficient to cover the advances, so a presumption arose that the advances were made from those funds rather than borrowed money; in the absence of a direct nexus, disallowance under section 36(1)(iii) was not justified. en-us Tue, 24 Mar 2026 00:00:00 +0530 Tue, 31 Mar 2026 08:27:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788907 Reopening under section 148 based on a revenue audit objection was held invalid where the original section 143(3) assessment had already examined the same loans and advances, and no new tangible material existed; the reassessment was therefore a mere change of opinion and the notice was quashed. On the interest issue, the assessee showed that its own capital, reserves and other interest-free funds were sufficient to cover the advances, so a presumption arose that the advances were made from those funds rather than borrowed money; in the absence of a direct nexus, disallowance under section 36(1)(iii) was not justified. Case-Laws Income Tax Tue, 24 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788907