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<h1>Supreme Court dismisses Special Leave Petition challenging assessment reopening; High Court decision upheld.</h1> The Supreme Court dismissed the Special Leave Petition as the re-opening of the assessment was considered a change of opinion by the Assessing Officer. ... Re-opening of assessment - change of opinion - finalisation of assessment - requirement to produce evidence in support of increase of authorised share capital and of share premiumRe-opening of assessment - change of opinion - finalisation of assessment - Validity of the reopening of assessment where the Assessing Officer had earlier called for evidence and had finalised the assessment - HELD THAT: - The Court accepted the High Court's conclusion that where the Assessing Officer, prior to completing the assessment, had called upon the assessee to produce evidence regarding increase of authorised share capital, share allotment and the sources/parties for share premium and thereafter finalised the assessment, a subsequent re opening of the same assessment amounted to a mere change of opinion. On that basis the High Court rightly set aside the re opening. The Supreme Court found no reason to interfere with that conclusion and dismissed the Special Leave Petition.Re opening held to be a change of opinion and therefore invalid; High Court order setting aside the re opening sustained.Final Conclusion: Special Leave Petition dismissed; pending applications disposed of. The Supreme Court dismissed the Special Leave Petition as the re-opening of the assessment was considered a change of opinion by the Assessing Officer. The High Court's decision to set aside the re-opening was upheld.