The assessee is  a credit co-operative society, registered as a State federal co-operative under section 33 of the 1997 Act. The assessee contended that it was entitled to deduction in respect of its income under S. 80P of the Act . on the premise that it was a co-operative society, on par with those registered under the provisions of the 1959 Act. The Department contended that the definition under section 2(19) mentioned of only a co-operative society and not a Souharda co-operative and that in the guise of judicial interpretation, the scope of the definition could not be widened than what was prescribed by Parliament and a stand in variance with that would have far reaching implications on the exchequer. On a writ petition to declare that the 1997 Act fell within the meaning of the words “any other law for the time being in force in any State for the registration of co-operative societies” as enumerated in section 2(19) of the 1961 Act . Allowing the petition the Court held that   a declaration was made to the effect that the entities registered under the 1997 Act fell into the definition of “co-operative society” as enumerated in section 2(19) of the 1961 Act and therefore subject to all just exceptions, the assessees were entitled to their claim for the benefit of section 80P . The notice issued under section 148 was to be quashed. Referred  Ujagar Prints v. UOI  ( 1989) 179 ITR 317 (SC)