Assessee claimed exemption under section 10(34) of the Act in respect of dividend income received from a trust formed pursuant to merger. During the course of assessment proceedings, all relevant facts were disclosed and accepted in scrutiny assessment under section 143(3) of the Act. Reassessment proceedings initiated after four years to disallow the exemption claimed on divided income is based merely on a change of opinion that the trust was not a company and not covered under section 115-O of the Act. Thus, notice issued under section 148 of the Act is without jurisdiction. SLP dismissed on account of delay of 124 days as well as on merits.