Reassessment cannot be made to disallow deduction allowed in Original Assessment

M/s. Kotarki Constructions Pvt. Ltd. Vs. Asst. CIT (Karnataka High Court) The powers of reassessment u/S.147/148 of the Act have to be invoked with great amount of circumspection and the relevant material on record, on the basis of which, a “reasonable opinion” can be framed in contrast with a mere “change of opinion” for initiating the reassessment proceedings. This Court is satisfied that there was no material on record before the Assessing Authority indicating any failure on the part of the assessee to truly and fully disclose the relevant material before the original Assessing Auth...