Against the order of the High Court allowing the assessee’s writ petition against a notice of reassessment and the order of reassessment passed pursuant thereto, and holding that it was not permissible for an Assessing Officer to reopen the assessment based on the very same material with a view to take another view thereon without consideration of material on record on the basis of which one view has conclusively been taken by the Assessing Officer, the Department filed a petition for special leave to appeal to the Supreme Court  dismissing the petition the Court held that  considering the fact that earlier the Assessing Officer had called upon the assessee to produce evidence in support of increase of authorised share capital, of share allotment and names and addresses of the parties from whom share premium was received, among other things, and thereafter, the Assessing Officer had finalised the assessment and passed assessment order, the subsequent reopening could be said to be a change of opinion. Under the circumstances, the reopening had been rightly set aside by the High Court. (AY.2013-14)