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<h1>Reopening of assessment on issue of shares at premium rejected as mere change of opinion; SLP dismissed.</h1> 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 ... Reopening of assessment u/s 147 - notice beyond the period of 4 years - Issue of shares at premium - reopening of assessment can be said to be change of opinion? - As decided by HC [2024 (7) TMI 446 - GUJARAT HIGH COURT] it cannot be said that any new or tangible material has come in possession of the revenue which was not truly and fully disclosed by the assessee at the time when the assessment proceedings were concluded. Accordingly, notice u/s 148 of the Act seeking reopening of the concluded assessment is nothing but mere change of opinion 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. 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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