Assessment of assessee-trust was completed under section 143(3) at ‘Nil’ income.Revenue audit party, however, objected to finalization of return of assessee-trust at ‘Nil’ for reason that during year, assessee received corpus donations which were not included in income for application under section 11.On basis of revenue audit objection, Assessing Officer issued notice under section 148   by issuing notice. On writ dismissing the petition the Court held that  with effect from 1-4-2022, audit objection is one of reasons for reopening assessment as per clause (ii) of Explanation 1 to section 148. Therefore, where revenue audit raised an objection that assessment was not completed in accordance with provisions of Act, it could not be treated as a change of opinion because this was statutory prescription and statutory ground/reason for reopening assessment as Assessing Authority had proceeded strictly in accordance with provisions of clause (ii) of Explanation 1 to section 148.  (AY. 2016-17)