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    <title>2024 (2) TMI 1659 - ITAT BANGALORE</title>
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    <description>Reopening of a completed assessment beyond four years was invalid because the recorded reasons did not specifically allege failure by the assessee to disclose fully and truly all material facts; the exercise was treated as a mere change of opinion without fresh material, so the reassessment was quashed. Interest income earned by a co-operative society from deposits with a co-operative bank was held deductible under section 80P(2)(d), the jurisdictional High Court view being applied and the contrary Supreme Court authority distinguished on its facts. The assessment and appellate orders were set aside, and relief was granted to the assessee on both jurisdictional and merits grounds.</description>
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      <description>Reopening of a completed assessment beyond four years was invalid because the recorded reasons did not specifically allege failure by the assessee to disclose fully and truly all material facts; the exercise was treated as a mere change of opinion without fresh material, so the reassessment was quashed. Interest income earned by a co-operative society from deposits with a co-operative bank was held deductible under section 80P(2)(d), the jurisdictional High Court view being applied and the contrary Supreme Court authority distinguished on its facts. The assessment and appellate orders were set aside, and relief was granted to the assessee on both jurisdictional and merits grounds.</description>
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