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“notice under section 148”

ReassessmentSection 148Section 1487,377 judgments

The decision most relied on for notice under section 148 is CIT v. Kabul Chawla (380 ITR 573), cited in 3,235 judgments on BharatTax.

Leading authorities on notice under section 148

CIT v. Kabul Chawla
380 ITR 573 · 2016 · High Court
3,235
citing judgments

In a search assessment under Section 153A, additions can only be made for completed or non-abated assessment years if incriminating material relevant to those years is found during the search, although notice under Section 153A(1) is mandatorily issued for six assessment years preceding the search.

CIT v. Sinhgad Technical Education Society
397 ITR 344 · 2017 · Supreme Court
1,589
citing judgments

For assessments under Section 153C, a notice is legally unsustainable if there is no incriminating material correlated to the specific assessment years for which reassessment is sought.

GKN Driveshafts (India) Ltd. v. ITO
259 ITR 19 · 2003 · Supreme Court
1,349
citing judgments

When a notice under Section 148 of the Income Tax Act is issued, the Assessing Officer is bound to furnish reasons for reopening upon the assessee's request and must dispose of the assessee's objections to the notice by passing a speaking order.

ACIT v. Rajesh Jhaveri Stock Brokers Pvt. Ltd.
291 ITR 500 · 2007 · Supreme Court
1,030
citing judgments

For initiating reassessment proceedings under Section 147, the Assessing Officer needs only prima facie material providing a reason to believe that income has escaped assessment. Conclusive proof or the sufficiency/correctness of the material is not required at the stage of issuing the notice under Section 148.

Raymond Woollen Mills Ltd. v. ITO
236 ITR 34 · 1999 · Supreme Court
862
citing judgments

For reassessment proceedings under Section 148, the Assessing Officer only needs prima facie material to have a reason to believe income has escaped assessment. Conclusive proof or evaluation of the sufficiency and correctness of such material is not required at the stage of issuing the notice.

Union of India v. Rajeev Bansal
469 ITR 46 · 2024 · Supreme Court
713
citing judgments

The legal fiction created by the Ashish Agarwal judgment stops the limitation clock for Section 148 notices from the date of the deemed notice. Orders issued without proper jurisdiction, or those inconsistent with statutory prescriptions, are a nullity, and there can be no waiver of such fundamental jurisdictional requirements.

Hindustan Lever Ltd. v. R.B. Wadkar
268 ITR 332 · 2004 · High Court
695
citing judgments

The validity of reassessment proceedings initiated under Section 147, by issuing a notice under Section 148, must be judged solely on the reasons originally recorded by the Assessing Officer. These recorded reasons cannot be supplemented, improved upon, or modified at any later stage.

Tin Box Company v. CIT
249 ITR 216 · 2001 · Supreme Court
624
citing judgments

When an issue is remitted to the Assessing Officer for fresh adjudication, the AO must conduct a de novo examination and provide the assessee a full opportunity of being heard. The assessee is bound to comply with the notices issued by the AO.

Judgments citing notice under section 148

Dy.Commissioner of Income Tax, Mumbai vs. Parinee Housing Pvt Ltd, Mumbai

In the result, appeal of the assessee is allowed and appeal of the Revenue is dismissed and cross objection of the assessee is allowed

ITA 3408/MUM/2023[2017-18]Status: DisposedITAT Mumbai09 May 2024AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)

Section 147Section 148Section 148ASection 185

High Court of Bombay challenging the validity of notice issued under section 148 under old provisions post 1st April 2021. The said notice under section 148 was quashed by the Hon'ble High Court of Bombay vide order dated 29 March 2022. 6. Subsequently, the Hon'ble Supreme Court ... assessee, order dated 22 July 2022 passed u/s 148A(d) of the Act disposed the objections filed by the assessee, along-with notice under section 148 was issued on the same date. 10. Thereafter, the ld. AO has treated the loan of Rs.69,00,000/- extended to the assessee company

Parinee Housing Private Limited, Vile Parle West vs. The Assistant Commissioner of Income-Tax - Cental Circle 2(4), Mumbai, New Marine Lines, Churchgate

In the result, appeal of the assessee is allowed and appeal of the Revenue is dismissed and cross objection of the assessee is allowed

ITA 2884/MUM/2023[AY 2017-18]Status: DisposedITAT Mumbai09 May 2024

Bench: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)

Section 147Section 148Section 148ASection 185

High Court of Bombay challenging the validity of notice issued under section 148 under old provisions post 1st April 2021. The said notice under section 148 was quashed by the Hon'ble High Court of Bombay vide order dated 29 March 2022. 6. Subsequently, the Hon'ble Supreme Court ... assessee, order dated 22 July 2022 passed u/s 148A(d) of the Act disposed the objections filed by the assessee, along-with notice under section 148 was issued on the same date. 10. Thereafter, the ld. AO has treated the loan of Rs.69,00,000/- extended to the assessee company

Usha Goyal, Delhi vs. DCIT, Circle-43(1), Delhi

In the result, the appeal of the assessee is allowed

ITA 3695/DEL/2023[2014-15]Status: DisposedITAT Delhi09 May 2024AY 2014-15

Bench: Shri Shamim Yahya & Shri Sudhir Pareekusha Goyal, Vs. Dcit, Circle 43 (1), 134/135, Vaishali, Pitampura, Delhi. Delhi – 110 034. (Pan : Aecpg5220J) (Appellant) (Respondent) Assessee By : None Revenue By : Shri Amit Katoch, Sr. Dr Date Of Hearing : 07.05.2024 Date Of Order : 09.05.2024 Order Per Shamim Yahya: This Appeal By The Assessee Is Directed Against The Order Of The Ld. Cit (Appeals)/National Faceless Appeal Centre (Nfac) Dated 26.06.2023 For The Assessment Year 2014-15. 2. Grounds Of Appeal Taken By The Assessee Read As Under :- “1. That On The Facts & In The Circumstances Of The Case, The Ld. Cit (A) Erred In Law & Facts In Confirming Penalty Imposed Of Rs.10,000/- U/S 271(1)(B) Of The Income Tax Act, 1961 Without Appreciating The Facts That There Was No Non- Compliance Of Notice Issued U/S 142(1) Of The Act Dated 06.11.2019 On The Scheduled Date 08.11.2019 As The Appellant Duly Filed Adjournment Before The Ld. Assessing Officer & Later On Filed All Requisite Details & Documents.

For Appellant: NoneFor Respondent: Shri Amit Katoch, Sr. DR
Section 139Section 142Section 142(1)Section 147Section 148Section 271(1)(b)Section 273BSection 274

declaring income of Rs.41,42,690/-. 2. The proceedings under section 147 of the Income Tax Act, 1961 were initiated and notice under section 148 of the Income Tax Act, 1961 dated 30.03.2019 was issued by ACIT, Circle 40 (1) to the appellant to file ITR. In response, appellant

DCIT, Faridabad vs. M/S. Vsb Investment Pvt. Ltd., Faridabad

In the result, the cross objection of the Assessee is allowed whereas the Revenue appeal is dismissed

ITA 467/DEL/2016[2006-07]Status: DisposedITAT Delhi09 May 2024AY 2006-07

Bench: Shri Pradip Kumar Kedia & Shri Yogesh Kumar Us

For Appellant: Shri Amit Sharma, AdvFor Respondent: Shri Vivek Kumar Upadhyay, Sr.DR
Section 143(3)Section 147Section 148Section 68

certain accommodation entries amounting to Rs.2,07,85,000/- from M/s. Basant Marketing Pvt. Ltd. Kolkata. The case was accordingly reopened vide notice under Section 148 dated 26.03.2013. Another notice under Section 148 was issued on 19.09.2013 and assessment was carried under Section 143(3) r.w. Section ... Assessing Officer as on 01.04.2013 with remarks ‘left’. In this regard, it was contended that in order to complete re-assessment, notice under Section 148 empowering the Assessing Officer to assume jurisdiction, has to be mandatorily served upon the assessee in accordance with Section 282(1) r.w. Order V, Rule

Income Tax Officer, Thane vs. Muljibhai Arjanbhai Sakaria, Thane

In the result, the appeal by the Revenue is allowed for statistical purposes

ITA 2794/MUM/2023[2011-12]Status: DisposedITAT Mumbai08 May 2024AY 2011-12

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: NoneFor Respondent: Smt. Smitha V. Nair
Section 133(6)Section 147Section 148Section 250

transaction of purchase bills from the entry provider, i.e. Sunita Wire and Cables, proceedings under section 147 of the Act were initiated and notice under section 148 of the Act was issued on 26/03/2018. During the assessment proceedings, the assessee was asked to provide the complete name and address

Deepak Switch Gears Pvt. Ltd., Kolkata vs. PCIT, Asansol

In the result, the appeal of the assessee stands allowed

ITA 809/KOL/2023[2012-13]Status: DisposedITAT Kolkata07 May 2024AY 2012-13

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.809/Kol/2023 Assessment Year: 2012-13 Deepak Switch Gears Pvt. Ltd….…......................…...……………....Appellant 48/6, Suman Villa, 2Nd Floor, 155, Jessore Road, Kolkata-700055. [Pan: Aabcd1131H] Vs. Pcit, Asansol….....….........................................................…..…..... Respondent Appearances By: Shri A. K. Tibrewal, Ar, Appeared On Behalf Of The Appellant. Shri Abhijit Kundu, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : April 08, 2024 Date Of Pronouncing The Order : May 07, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Revision Order Dated 30.12.2022 Of The Principal Commissioner Of Income Tax, Kolkata [Hereinafter Referred To As ‘Pr. Cit’] Passed U/S 263 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). The Assessee In This Appeal Has Agitated Against The Action Of The Pr. Cit In Exercising His Revision Jurisdiction U/S 263 Of The Act & Thereby Directing The Assessing Officer To Frame The Assessment Afresh. 2. The Registry Has Pointed Out That The Appeal Is Time-Barred By 158 Days. A Separate Application Of Condonation Of Delay Has Been Filed, Wherein, It Has Been Pleaded That After Receipt Of The Impugned Order Of The Pr. Cit, The Assessee, Through Its Director, Shri Deep Kishan Saraf, Immediately Approached One Shri Pawan Kumar Agarwal, Chartered

Section 253Section 263Section 5

Subsequently, the assessment was reopened based on the information received from the DDIT (Investigation) Unit 2(2), Kolkata dated 6-3-2019. Thereafter, notice under section 148 of the Act was issued on 29-3-2019 and in response to such notice the assessee filed its return of income declaring

ITO, Ward-6(1), Kolkata vs. M/S Daniel Commodities Pvt. Ltd., Kolkata

ITA 645/KOL/2020[2009-10]Status: DisposedITAT Kolkata07 May 2024AY 2009-10

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.645/Kol/2020 Assessment Year: 2009-10 Ito, Ward-6(1), Kolkata………..…….......................…...……………....Appellant Vs. M/S Daniel Commodities Pvt. Ltd…..........…..........................…..…..... Respondent 6, Lyons Range, Kolkata – 1. [Pan: Aaccd9344F] C.O. 4/Kol/2023 (A/O I.T.A. No.645/Kol/2020) Assessment Year: 2009-10 M/S Daniel Commodities Pvt. Ltd…………….....................…..…..... Cross-Objector 6, Lyons Range, Kolkata – 1. [Pan: Aaccd9344F] Vs Ito, Ward-6(1), Kolkata …………….......................…...……………....Respondent Appearances By: Shri Abhijit Kundu, Cit-Dr, Advocate, Appeared On Behalf Of The Department. Shri Miraj D. Shah, Ar, Appeared On Behalf Of The Assessee. Date Of Concluding The Hearing : February 23, 2024 Date Of Pronouncing The Order : May 07, 2024

Section 143(1)Section 144Section 147Section 148Section 151Section 250Section 263

provisions of Section 147 dealing with re- assessment. The facts were that the assessment was sought to be reopened under Section 147 and notice under section 148 was issued. Validity of I.T.A. No.645/Kol/2020 & C.O. 4/Kol/2023 Assessment Year: 2009-10 M/s Daniel Commodities Pvt. Ltd reopening was not challenged upto Tribunal

Arvind Kumar Taneja (HUF), New Delhi vs. ITO, Ward-52(4), New Delhi

In the result, the appeal of the assessee is allowed

ITA 842/DEL/2023[2011-12]Status: DisposedITAT Delhi07 May 2024AY 2011-12

Bench: Sh. Kul Bharatdr. B. R. R. Kumar

For Appellant: Sh. Shreyansh Kushwaha, AdvFor Respondent: Sh. Kanv Bali, Sr. DR
Section 133(6)Section 139Section 139(1)Section 142Section 148Section 153Section 271Section 271(1)(c)

that such person furnishes a return of his income at any time after the expiry of the period aforesaid in pursuance of a notice under section 148.” 7. The AO has recorded in concluding para 3.1 of the impugned penalty order that the "revised computation of income was filed

Svarna Textiles Ltd., Kolkata vs. ITO, Ward-12(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 187/KOL/2024[2017-18]Status: DisposedITAT Kolkata06 May 2024AY 2017-18

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Girish Agrawali.T.A. No. 187/Kol/2024 Assessment Year: 2017-2018 Svarna Textiles Limited,…....………………….Appellant 7, Old Ballygunge, 2Nd Lane, Ballygunge, Kolkata-700019 [Pan:Aarcs6490A] -Vs.- Income Tax Officer,…….…………………….…Respondent Ward-12(1), Kolkata, Aayakar Bhawan, P-7, Chowringhee Square, Kolkata-700069 Appearances By: Shri S.K. Pransukha, Fca, Appeared On Behalf Of The Assessee Shri Supriya Pal, Addl. Cit, D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing : April 10, 2024 Date Of Pronouncing The Order : May 6, 2024 O R D E R

Section 131Section 139(1)Section 143(2)Section 148

deposit of Rs.10,05,000/-. It did not file income-tax return under section 139(1). The ld. Assessing Officer has issued a notice under section 148 of the Income Tax Act inviting the return of income within thirty days, which was filed by the assessee declaring total income

Unicorn Infoservices Private Limited, Mumbai vs. National Faceless Appeals Centre, New Delhi

In the result, the regular ground raised by the

ITA 4190/MUM/2023[2011-12]Status: DisposedITAT Mumbai06 May 2024AY 2011-12

Bench: Shri Om Prakash Kant () & Shri Narender Kumar Choudhry () Assessment Year: 2011-12

For Appellant: Mr. Vickey Chedda/Mr. Jainam GalaFor Respondent: 02/05/2024
Section 148Section 271(1)(c)Section 274

income at any time after the expiry of the period aforesaid in pursuance of a notice under period aforesaid in pursuance of a notice under section 148 section 148.” 7.1 We find that in the instant case, the assessee has explained We find that in the instant case, the assessee

ITO, W-6(5), Mohali vs. Smt. Gurdev Kaur, Kharar

In the result, the appeal of the Revenue is dismissed

ITA 1448/CHANDI/2019[2010-11]Status: DisposedITAT Chandigarh03 May 2024AY 2010-11

Bench: Disposal Of Appeal.”

For Appellant: Shri Tej Mohan Singh, AdvocateFor Respondent: Smt. Amanpreet Kaur, Sr. DR
Section 143(2)Section 144Section 148

Patiala and as the assessee has not filed any return of income, the same were not verifiable, thereafter reasons were recorded and notice under section 148 was issued to the assessee. 5. In response to the notice, assessee filed his return of income declaring income under the head “agriculture income

Ajmer Singh, Mohali vs. ITO, W-6(5), Mohal

In the result, the appeal of the Revenue is dismissed

ITA 1439/CHANDI/2019[2011-12]Status: DisposedITAT Chandigarh03 May 2024AY 2011-12

Bench: Disposal Of Appeal.”

For Appellant: Shri Tej Mohan Singh, AdvocateFor Respondent: Smt. Amanpreet Kaur, Sr. DR
Section 143(2)Section 144Section 148

Patiala and as the assessee has not filed any return of income, the same were not verifiable, thereafter reasons were recorded and notice under section 148 was issued to the assessee. 5. In response to the notice, assessee filed his return of income declaring income under the head “agriculture income

Ajmer Singh, Mohali vs. ITO, W-6(5), Mohal

In the result, the appeal of the Revenue is dismissed

ITA 1438/CHANDI/2019[2010-11]Status: DisposedITAT Chandigarh03 May 2024AY 2010-11

Bench: Disposal Of Appeal.”

For Appellant: Shri Tej Mohan Singh, AdvocateFor Respondent: Smt. Amanpreet Kaur, Sr. DR
Section 143(2)Section 144Section 148

Patiala and as the assessee has not filed any return of income, the same were not verifiable, thereafter reasons were recorded and notice under section 148 was issued to the assessee. 5. In response to the notice, assessee filed his return of income declaring income under the head “agriculture income

Gillanders Arbuthnot and Co. Ltd, 2009-10 vs. ACIT, Cir-4(1), Kol, Kolkata

The appeal of the assessee is allowed

ITA 495/KOL/2023[2014-15]Status: DisposedITAT Kolkata03 May 2024AY 2014-15

Bench: Dr. Manish Borad & Shri Sonjoy Sarma

Section 115JSection 133(6)Section 143(3)Section 147Section 148

with M/s. S.R. Sales corporation, after Assessment Years: 2009-10, 2013-14 & 2014-2015 Gillanders Arbuthnot And Co. Limited recording the reasons, notice under section 148 of the Act was issued and duly served upon the assessee. The assessee raised objection, which was considered. The ld. Assessing Officer during ... case was scrutinized under section 143(3) of the Act. After four years of the assessment year in question, the assessee was issued notice under section 148 of the Act for the following reasons:- “Reason for issuance of notice u/s 148 The assessment in the case of the assesse

Gillanders Arbuthnot and Co. Ltd, 2009-10 vs. ACIT, Cir-4(1), Kol, Kolkata

The appeal of the assessee is allowed

ITA 494/KOL/2023[2013-14]Status: DisposedITAT Kolkata03 May 2024AY 2013-14

Bench: Dr. Manish Borad & Shri Sonjoy Sarma

Section 115JSection 133(6)Section 143(3)Section 147Section 148

with M/s. S.R. Sales corporation, after Assessment Years: 2009-10, 2013-14 & 2014-2015 Gillanders Arbuthnot And Co. Limited recording the reasons, notice under section 148 of the Act was issued and duly served upon the assessee. The assessee raised objection, which was considered. The ld. Assessing Officer during ... case was scrutinized under section 143(3) of the Act. After four years of the assessment year in question, the assessee was issued notice under section 148 of the Act for the following reasons:- “Reason for issuance of notice u/s 148 The assessment in the case of the assesse

Gillanders Arbuthnot and Co. Ltd, 2009-10 vs. ACIT, Cir-4(1), Kol, Kolkata

The appeal of the assessee is allowed

ITA 493/KOL/2023[2009-10]Status: DisposedITAT Kolkata03 May 2024AY 2009-10

Bench: Dr. Manish Borad & Shri Sonjoy Sarma

Section 115JSection 133(6)Section 143(3)Section 147Section 148

with M/s. S.R. Sales corporation, after Assessment Years: 2009-10, 2013-14 & 2014-2015 Gillanders Arbuthnot And Co. Limited recording the reasons, notice under section 148 of the Act was issued and duly served upon the assessee. The assessee raised objection, which was considered. The ld. Assessing Officer during ... case was scrutinized under section 143(3) of the Act. After four years of the assessment year in question, the assessee was issued notice under section 148 of the Act for the following reasons:- “Reason for issuance of notice u/s 148 The assessment in the case of the assesse

Income Tax Officer, Mumbai vs. Svadeshi Enterprise(Hubli), Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 2785/MUM/2023[2014-15]Status: HeardITAT Mumbai03 May 2024AY 2014-15

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Rahul Chaudhary, Hon'Bleincome Tax Officer V. Svadeshi Enterprise(Hubli) R.N. 234, 2Nd Floor 12/A Yusuf Building Kautilya Bhawan, Bkc Veer Nariman Road, Fort Mumbai, Maharashtra- 400051 Mumbai-400023 Pan: Aapfs0181B (Appellant) (Respondent) Assessee Represented By : Shri Vijay Mehta Shri Veerbhandra Mahajan Department Represented By :

Section 143(1)Section 143(3)Section 147Section 148

that the Page No. 14 Svadeshi Enterprise(Hubli) Assessing Officer ought to have considered the objection now raised in the grounds for issuing notice under Section 148 of the Act, during the original assessment proceedings. ” The aforesaid observations will apply to the first grievance of the Revenue before ... assessment proceeding? (C) Whether, on the facts and the circumstances of the case, the Tribunal was justified in holding that the issue of notice under Section 148 after the issue of under Section 154 is bad in law?” 14. And the Hon’ble High Court answered as under: - “QUESTIONS

Picasa Facility Management, New Delhi vs. ITO, Ward 36(1), Delhi

In the result appeal of the assessee is allowed

ITA 103/DEL/2024[2015-16]Status: DisposedITAT Delhi03 May 2024AY 2015-16

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarasstt. Year: 2015-16 Picasa Facility Management Vs. Acit, C/O D D Nagpal, Central Circle-2, Chartered Accountant, New Delhi. Gh Gopala Tower, 25, Rajendra Place New Delhi – 110 008 Pan Aamfp00803A (Appellant) (Respondent)

For Appellant: Shri J.S. Kochar, CAFor Respondent: Ms. Mayuri, Sr. DR
Section 147Section 148Section 151Section 151(1)

information with the Department proceedings under section 147 of the Income Tax Act, 1961 were initiated after recording reasons by the Assessing Officer. Notice under section 148 of the Act was issued on 31.03.2021. The reassessment under section 147/144B was completed on 26.03.2022 by assessing income of Rs.52 ... representative submitted that although more than four years had elapsed from the end of relevant assessment year the sanction for issuance of notice under section 148 was neither sought nor obtained from the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner of Income Tax who were

Pushpa Joshi, Uttar Pradesh vs. AO Ward 5(2)(4), Gautam Budh Nagar

ITA 901/DEL/2022[2011-12]Status: DisposedITAT Delhi03 May 2024AY 2011-12

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarasstt. Year: 2011-12 Pushpa Joshi Vs. Ao, Ward5(2)(4) D-170 Sector-27, Noida Gautam Budh Uttar Pradesh 201 301 Nagar Pan Aeepj0375H Uttar Pradesh (Appellant) (Respondent)

For Appellant: Shri Sanjeev Jain, CAFor Respondent: Shri Vivek Vardhan, Sr. DR
Section 142(1)Section 147Section 148Section 234ASection 271(1)(c)

financial year 2010-11 relating to assessment year 2011-12 and therefore proceedings under section 147 of Income Tax Act were initiated. Despite notice under section 148 dated 23.03.2018 no compliance was made. Thereafter notice under section 142(1) of the Income Tax Act, 1961 along with questionnaire was issued ... exparte. 4. Hence present appeal by assessee. 5. Learned Representative for assessee filed application for additional ground of appeal i.e. “That no notice under section 148 was served on the assessee as the same was sent on an unknown address and therefore the impugned assessment order passed under section

M/S Santhimadom Ayurnikethan Health Resort & Research Institute Trust, Kochi vs. ACIT Central Circle -2, Kochi

In the result, the assessee’s appeals are allowed for statistical purposes

ITA 919/COCH/2022[2009-10]Status: DisposedITAT Cochin02 May 2024AY 2009-10

Bench: Shri Sanjay Arora & Ms. Kavitha Rajagopal

For Appellant: Shri Mathew Joseph, CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. DR
Section 153ASection 153CSection 234A

under section 140A towards the interest chargeable under this section. (3) Where the return of income for any assessment year, required by a notice under section 148 or section 153A issued after the determination of income under sub- section (1) of section 143 or after the completion of an assessment