Assessee filed its return of income was selected for scrutiny and an assessment order under section 143(3) was passed, making additions under section 68.Reopening notice was issued on ground that assessee had not disclosed fully and truly all facts and details with regard to trading done through broker and as such, return was processed under section 143(1) and no scrutiny assessment was passed under section 143(3). On writ the Court held that   at time when assessment order under section 143(3) was passed, Assessing Officer was in possession of transaction details through broker and thereby, same could not be made subject matter again to assume jurisdiction under section 148 for reopening of assessment, as same had already been concluded. High Court  held that reopening notice was nothing but change of opinion and same was not permissible in law.  There was gross delay of 185 days in filing SLP. Court held that  since delay had not been satisfactorily explained and even otherwise, there was no reason to interfere with impugned order passed by High Court, SLP filed by revenue was to be dismissed on ground of delay as well as on merits. (AY. 2011-12)