ACIT vs Mahalaxmi Chemical Works The notice under s.148 was issued for the reason that interest paid was not allowable since funds taken on interest were not used for business purpose.During reassessment said interest was not disallowed, accepting the assessee’s explanation. The reassessment for that reason could not be held to be invalid since there was prima facie reason to believe at the time of issue of notice under s.148 that income had escaped assessment.