Reopening of assessment on issue of shares at premium rejected as mere change of opinion; SLP dismissed.

Reopening of assessment for issue of shares at premium was challenged as beyond four-year period and constituting merely a change of opinion. The High Court found no new or tangible material that was not disclosed earlier, so the reopening notice under the income tax law was treated as change of opinion and therefore unsustainable. The Supreme Court refused to exercise discretionary jurisdiction under constitutional powers and dismissed the special leave petition, leaving the High Court decision intact and the reopening notice quashed.

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This short Supreme Court order notes that after hearing counsel, "Delay condoned." The Court held that "No case for interference is made out in exercise of our jurisdiction under Article 136 of the Constitution of India. The Special Leave Petition is accordingly dismissed." The order concludes that pending application(s), if any, "stand disposed of." Procedurally, the decision reflects denial of discretionary relief under Article 136 and termination of ancillary applications; no substantive legal issues were entertained for interference. The entry functions as a dismissal order without precedent-setting reasoning.

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