https://www.taxtmi.com/caselaws?id=787962 Reopening of assessment under section 147 in relation to disallowance of deduction under section 80P(2)(d) was considered against interest income from fixed deposits with a cooperative bank. The Gujarat High Court noted that, where the underlying issue had already been decided in favour of the assessee in Ashwinkumar Arban Co-operative Society Ltd., the assessment could not be reopened on that basis. The Supreme Court record further notes that the special leave petition was filed 225 days late, the explanation for delay was found insufficient, and the delay-condonation application was rejected, resulting in dismissal of the special leave petition as time-barred. en-us Wed, 11 Mar 2026 00:00:00 +0530 Sat, 14 Mar 2026 08:36:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787962 Reopening of assessment under section 147 in relation to disallowance of deduction under section 80P(2)(d) was considered against interest income from fixed deposits with a cooperative bank. The Gujarat High Court noted that, where the underlying issue had already been decided in favour of the assessee in Ashwinkumar Arban Co-operative Society Ltd., the assessment could not be reopened on that basis. The Supreme Court record further notes that the special leave petition was filed 225 days late, the explanation for delay was found insufficient, and the delay-condonation application was rejected, resulting in dismissal of the special leave petition as time-barred. Case-Laws Income Tax Wed, 11 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787962