Mumbai Postal Employees Co-operative Credit Society Ltd. v. ITO [2023] 149 taxmann.com 94 / 292 Taxman 492 (Bom)(HC)

S. 147 : Reassessment–After the expiry of four years- Co-operative Society-Deduction allowed- Change of opinion–Reassessment notice and order disposing the objection was quashed. [S. 80P(2)(1), 80P(2)(d), 148, 226]

Allowing the petition the Court held that issue with regard to claim of deduction under section 80P had been specifically gone into by Assessing Officer leading to passing of assessment order under section 143(3) and consequent thereto, there had been neither any change in law nor any new material had been shown to have come to knowledge of Assessing Officer, reopening of assessment on ground that claim of deduction under section 80P(2)(d) was not in conformity with provisions of said section being a mere change of opinion was not justified.(AY. 2014-15)