The assessment was sought to be reopened by a notice under section 148 based on information from the Investigation Wing, which alleged that the assessee had received bogus share premium. In response, the assessee submitted its balance sheet, demonstrating that there was no change in its share capital and no such amount had been received as share premium. The ITO nevertheless rejected the objections. The High Court quashed the reopening proceedings. It held that a bare perusal of the assessee’s balance sheet showed that the alleged transaction did not exist, thereby breaking any “live link” or “nexus” between the information received and the formation of a belief that income had escaped assessment. As no new tangible material was available on record, the Court concluded that the reopening was a clear case of a “change of opinion” and was therefore not justified. (AY. 2009-10)