Assessee is an educational institution and a deemed university, was in existence from 1957. It did not file return for assessment year 2015-16, as there was no necessity to submit return till assessment year 2015-16. Pursuant to amendment to section 139(4C)(e) filed returns for assessment years 2016-17 to 2018-19 and in all these years Assessing Officer accepted that assessee was a section 10(23C)(iiiab) institution entitled for exemption. Later on Assessing Officer passed notice under section 148A on assessee for reasons that it failed to substantiate claim towards its compliance with conditions imposed in section 10(23C)(iiiab) and it was holding huge amount of fixed deposits. On writ allowing the petition the Court held that since assessee was catering to needs of several lakhs of students and was having a huge infrastructure, holding fixed deposits running to several crores of rupees could not be a ground for reopening assessment that too when Assessing Officer himself had treated assessee as a section 10(23C)(iiiab) institution entitled for exemption in respect of subsequent assessment years 2016-17 to 2018-19. Accordingly  the  order passed under section 148A(d) and notice issued under section 148  of the Act was quashed.   (AY. 2015-16)