Reopening of assessment unsustainable as prerequisite for reopening beyond four years not fulfilled

DCIT Vs Gujarat State Road Development Corporation Ltd (ITAT Ahmedabad) ITAT Ahmedabad held that reopening of assessment under section 147 of the Income Tax Act is unsustainable as prerequisite laid down in law for reopening of the case beyond four years is not found to be fulfilled. Facts- The reopening had been resorted to by an order passed in terms of provision of section 147 of the Act on an identical issue. The addition so made by the AO had been challenged before the ld.CIT(A) both on legal ground challenging validity of the assessment framed ,as well as on merits of the additions made;...