80P Disallowance

The Karnataka High Court set aside reassessment proceedings, consequential demand notices, and bank account attachment orders initiated against Prathamika Krishi Pathina Sahakara Sangha Niyamitha after observing that the assessee had not participated in reassessment proceedings and claimed to possess material establishing eligibility for exemption under Section 80P(2) of the Income Tax Act. 

The Court held that an opportunity ought to be granted to the petitioner to substantiate its claim that deposits treated as unexplained by the Revenue were in fact deposits of farmer-members eligible for exemption. 

Accordingly, the matter was remanded to the stage of reply to notice under Section 148A(b), while also directing immediate withdrawal of bank attachment instructions issued under recovery proceedings.