Allowing the petition the Court held that the assessee had supplied all relevant material in nature of accounting entries, resolution passed, names of allottees and their addresses and PAN numbers during original scrutiny assessment, which had satisfied Assessing Officer at relevant time about genuineness of entities and share transactions. The  amount of share application was received by cheque or through mode of RTGS. Assessee had furnished all material information truly and fully during original scrutiny assessment.On facts, impugned reopening of assessment after four years on basis of same information amounted to change of opinion which is not permitted under law(AY. 2011-12)