Allowing the petition, the Court held that assessment in case of assessee-company was reopened on issue of fair market value (FMV) of rights shares issued by assessee, since Assessing Officer had accepted assessee’s method of determining FMV during original assessment and recorded his satisfaction in assessment order, impugned reopening notice issued under section 148 after expiry of four years on mere change of opinion was liable to be set aside. Notice and order disposing the objection was quashed.  SLP of revenue is dismissed. (AY. 2015-2016)