https://www.taxtmi.com/caselaws?id=789709 Where a return was processed only under Section 143(1) and no assessment was made under Section 143(3), reassessment under Section 147 was not barred by change of opinion, and the Tribunal could examine a jurisdictional issue within the appeal's subject matter. The Court also applied the principle that interest earned on deposits is capital in nature when the funds are raised and deployed for project-related purposes in setting up the business, including technical know-how, land, raw materials, and machinery advances. Such interest was held to reduce pre-operative expenses rather than be taxed as income from other sources. The reassessment issue was sustained, while the interest-income issue was decided for the assessee. en-us Fri, 10 Apr 2026 00:00:00 +0530 Mon, 13 Apr 2026 07:52:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789709 Where a return was processed only under Section 143(1) and no assessment was made under Section 143(3), reassessment under Section 147 was not barred by change of opinion, and the Tribunal could examine a jurisdictional issue within the appeal's subject matter. The Court also applied the principle that interest earned on deposits is capital in nature when the funds are raised and deployed for project-related purposes in setting up the business, including technical know-how, land, raw materials, and machinery advances. Such interest was held to reduce pre-operative expenses rather than be taxed as income from other sources. The reassessment issue was sustained, while the interest-income issue was decided for the assessee. Case-Laws Income Tax Fri, 10 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789709