Assessments can be reopened based on a special audit report, despite valid Section 143(3) orders, u/ss 147 and 148.

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....Reopening of assessment - special audit report as basis for reopening - though the orders of assessment passed u/s 143(3) have sanctity attached, it does not grant immunity to an assessee from proceedings for reopening of assessment year of Section 147 / 148, provided the jurisdictional requirements therein are satisfied, at the time when the reopening notice is issued - HC....