Allowing the petition the court held that  issue with regard to rise in share premium was discussed during the course of assessment proceedings and the said issue was well within the mind of the then Assessing Officer at the time of scrutiny assessment. In view thereof, it would not be now permissible for the Department to reopen the concluded assessment proceedings on the same issue and details. No new or tangible material had come into the possession of the Department which was not truly and fully disclosed by the assessee at the time when the assessment proceedings were concluded. Accordingly, the notice under section 148 of the Act seeking reopening of the concluded assessment was based on nothing but a mere change of opinion. The notice under section 148 seeking to reopen the assessment for the assessment year 2015-2016 was quashed and set aside.(AY. 2015-16)