Auditor’s opinion on Section 80P Interpretation, cannot be a Information for Reopening U/s 147

The  case of assessee was reopened and the assessment under section 144 read with section 147 of the IT Act, 1961. While framing the assessment, the AO restricted the deduction claimed u/s 80P(2)(c)(i) of the Act  and also confirmed the disallowance u/s 40(a)(ia)  consequent to  deposit of TDS after due date of filing of return for the AY 2009-10.  Appellant challenged the reopening of the case on the ground that  reopening of a case assessed u/s 143(3)  within 4 years requires the sanction of Additional Commissioner u/s 151 instead of sanction accorded by CIT. Such reopening  been fur...