Assessee-company was functioning as a holding company with 90.41 per cent of total assets invested in shares of other companies for the purpose of holding a stake. Assessing Officer reopened the assessment on the ground that excess investment was to be brought to tax under section 69 and interest on borrowed funds which were not utilised for business purposes was to be disallowed. He further took a stand that securities premium should not have been invested in subsidiary companies and the amount of suo motu disallowance made by the assessee under section 14A had been wrongly adjusted. On writ, the High Court held that since the reasons for reopening made it clear that it was merely a change of opinion, the reopening notice could not be sustained. SLP of revenue is dismissed on account of failure to explain the delay of 498 days.  (AY. 2015-16)