1994 (7) TMI 14

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..... r dated January 1, 1985, in respect of the assessment years 1977-78, 1978-79 and 1979-80: "Whether, on the facts and in the circumstances of the case, the Tribunal was legally justified in holding that the assessment completed for the first time under section 143(3) of the Income-tax Act, 1961, in pursuance of issue of notice under section 148 can be termed as reassessment and the assessment com .....

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..... the words "regular assessment" would not cover an assessment which has been made under section 147/148 of the Act and as such the assessment or reassessment made under section 147 is not a regular assessment in which the liability of interest in terms of section 217 could be fastened. Accordingly, it is held that the Income-tax Appellate Tribunal was justified in holding that the assessment comp .....

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