ORDER :

(PER : HONOURABLE MR. JUSTICE NIRAL R. MEHTA)

[1] By way of this petition under Article 226 of the Constitution of India, the petitioner has challenged the notice issued by the respondent – Revenue under Section 148 of the Income Tax Act, 1961 (for short, “the Act”) dated 27th March 2021, thereby the reassessment sought to be initiated for the Assessment Year 2014- 15.

[2] The brief facts of the case can be stated as under:

[2.1] The petitioner is a cooperative society registered under the Cooperative Societies Act. The petitioner filed its original return of income for the Assessment Year 2014-15 on 25th November 2014 declaring total income at Rs.Nil. The case of the petitioner was then processed and also selected for scrutiny. A detailed scrutiny was undertaken. A notice under Section 142(1) of the Act dated 8th April 2016 was issued asking specific details relating to deduction claimed under Chapter VI-A. In furtherance thereto, the petitioner submitted complete details of deduction claimed under Section 80P of the Act vide its letter filed somewhere in May 2016.

[2.2] The then Assessing Officer, having considered all the material produced on record, framed the assessment und