https://www.taxtmi.com/caselaws?id=797851 Prior approval under section 151 must be obtained before issuing a notice under section 148; approval obtained afterwards invalidates the assumption of reassessment jurisdiction. Reassessment also cannot sustain independent additions where no addition survives on either of the recorded reasons for reopening. Interest on delayed payment of indirect taxes, including excise duty and service tax, is compensatory and allowable as a business deduction because section 40(a)(ii) applies to direct taxes. Where interest-free own funds substantially exceed interest-free advances, the advances are presumed to be funded from own funds and no interest disallowance arises under section 36(1)(iii). en-us Fri, 21 Aug 2026 00:00:00 +0530 Fri, 28 Aug 2026 20:42:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797851 Prior approval under section 151 must be obtained before issuing a notice under section 148; approval obtained afterwards invalidates the assumption of reassessment jurisdiction. Reassessment also cannot sustain independent additions where no addition survives on either of the recorded reasons for reopening. Interest on delayed payment of indirect taxes, including excise duty and service tax, is compensatory and allowable as a business deduction because section 40(a)(ii) applies to direct taxes. Where interest-free own funds substantially exceed interest-free advances, the advances are presumed to be funded from own funds and no interest disallowance arises under section 36(1)(iii). Case-Laws Income Tax Fri, 21 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797851