1999 (10) TMI 18

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....rred the following question for the opinion of this court : "Whether, in the course of making reassessment after having validly initiated reassessment proceedings under section 147(a) of the Income-tax Act, 1961, in respect of certain items of escaped income, the Income-tax Officer can also add/disallow in computing the total income of the assessee certain other items which were allowed by him at....

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....ding to him, should not have been allowed by the Income-tax Officer making the original assessment. It is not the case of the Income-tax Officer that such allowances were made on account of non-disclosure of any facts by the assessee. The disallowances were made by the subsequent officer only because he was of a different opinion." The Tribunal held that in reassessment proceedings, this could no....