Reopening Based on change of opinion and in absence of any adverse tangible material was invalid

DCIT Vs Surat Urban Development Authority (SUDA) (ITAT Ahmedabad) A perusal of the above would indicate that in all these three years, assessments have been framed under section 143(3) of Act. Notice under section 148 of the Income Tax Act was issued after expiry of four years from the end of the relevant year in the Asstt. Year 2009-10 and 2010-11. AO has recorded reasons on 1.12.2015 in both these years. As far as Asstt. Year 2011-12 is concerned, notice under section 148 was issued on 14.3.2016 i.e. within four years from end of the assessment year. Thus, as far as Asstt. Year 2009-10 and 2...