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The object of the assessee is similar to that of the corporation before the Jurisdictional High Court and on the similar set of facts the appeal was allowed in favour of the assessee hence relying upon the same we allow the claim of the assessee and the disallowance of exemption as claimed by the assessee u/s 11 of the Act to the tune of Rs. 70,73,005/- is hereby quashed and addition made thereon is thus deleted.

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Sec. 147 of Income Tax Act, 1961— Re-assessment — AO has simply gone though the record already available to him on the basis of which a scrutiny assessment framed under section 143(3) and AO himself recorded a finding that after discussion and from the data made available during the course of hearing nothing adverse has been found and all the information called under section 142(1) relating to the important activities, income claimed under section 11 were submitted as well as books of accounts supported by bills and vouchers were produced before the AO for verification, therefore, assessment cannot be reopened. - DEPUTY CIT V/s GANDHINAGAR URBAN DEVELOPMENT AUTHORITY - [2020] 207 TTJ 017 (UO)(ITAT-AHMEDABAD)