Deduction Disallowance Must Occur in Regular Assessment, Not Rectification u/s 154; It's a Debatable Issue.

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....Disallowance of deduction - AO should have made disallowance only while framing regular assessment or reassessment, which was made prior to resorting to this rectification. This disallowance cannot be made while acting u/s.154 of the Act reason being this is not a prima facie mistake it is a highly debatable issue - HC....