Allowing the petition the Court held that the assessee had furnished details relating to Broadcom Communications Technologies Ltd.  After  details were furnished, the assessment order was issued on November 22, 2016 without any additions, or rejection. The notice of reassessment had been issued because the Assessing Officer was of the opinion that though the assessee had paid sub-contractor charges to Broadcom Communications Technologies Ltd., the assessee had not deducted the tax at source for the entire amount. On this issue it had to be presumed that there had been conscious application of mind and therefore a deemed opinion, and there could not be reassessment only because an error in such opinion. The reason offered by the Assessing Officer to justify the reassessment could not be accepted as an objective view based on any subsequent information in the absence of necessary material in this regard. The notice of reassessment was not valid. (AY.2014-15) (SJ)