ORDER : S.H. Kapadia, CJI., K.S.P. Radhakrishnan, Swatanter Kumar, JJ. In our view, the reopening of assessment is fully justified on the facts and circumstances of the case. 2. However, on the merits of the case, it would be open to the Assesses to raise all contentions with regard to the amount of Rs. 98.46 lakhs being offered for tax as well as its contention on Section 14A of the Income-tax Act, 1961. 3. Subject to the above, the special leave petition is dismissed.