Assessee had received share application money at premium.  The assessment was completed under section 143(3) of the act and specif issue of share premium was raised in the Course of assessment proceedings. Reopening notice was issued on ground that share premium was charged on basis of projections which were not achieved and there was no connection between actual figures and figures considered for valuation of shares. On writ allowing the petition the Court held that  during original assessment proceedings, subject matter of large share premium received during year was under active consideration of Assessing Officer.Since very issue of share premium was subject matter of consideration by Assessing Officer during original assessment proceedings, reopening of assessment was merely on basis of change of opinion and thus not sustainable.  (AY. 2014-15)