In the absence of pending return of income, the provisions of section 143(2) of the Act is clear that notice can be issued only when a valid return is pending for assessment. Accordingly, this notice has no meaning
Can a S. 143(3) assessment be reopened u/s 147 despite full disclosure of facts?
In Income-Tax Officer V/s. Techspan India Private Limited and Another, reported in  404 ITR 10(SC), the Supreme Court reiterated the settled principle of law laid down by the Supreme Court in CIT V/s. Kelvinator of India Ltd.  320 ITR 561(SC) that the Assessing Officer has a power only to reassess and has no power to review the assessment order. Thus, it held that no re-opening notice can be issued which is premised on a change of opinion