Dismissing the appeal of the revenue the Court held that   all the particulars relating to dividends and short-term capital gains and other particulars were available with the Assessing Officer during the assessment proceedings, which were concluded under section 143(3) of the Act. The Tribunal, on the facts, had recorded that the Department did not bring any material fact before it, which was not disclosed in the original return of income. The reopening of the assessment beyond four years was clearly a case of change of opinion. The reassessment was not valid. (AY. 2008-09)