Assessee, co-operative society, claimed deduction under section 80P which was allowed.  Assessing Officer issued notice under section 147  to propose disallow the claim and also passed the assessment order disallowing the claim.  The assessee had challenged reassessment notice after re-assessment order was passed and moreover after lapse of time for filing statutory appeal. Dismissing the petition the Court held that  there was delay in statutory audit by State Government or whether assessee at all requested State Government for statutory audit, whether assessee prepared statement of accounts, etc. and submitted to Registrar, required factual adjudication which was beyond scope of proceedings under Article 226 of Constitution of India. Accordingly  the  assessee is  not entitled to invoke extra-ordinary writ jurisdiction of High Court having not availed alternative remedy as provided for under Act. (AY. 2013-14,  2014-15)