ORDER : 1. Considering the fact that earlier the Assessing Officer had called upon the petitioner(s) to produce the evidence in support of increase of authorised share-capital, produce the evidence of share allotment and names and addresses of the parties from whom share-premium was received, among other things and thereafter, the Assessing Officer finalised the assessment and passed Assessment Order, the subsequent re-opening can be said to be change of opinion. Under the circumstances, the re-opening is rightly set aside by the High Court. We see no reason to interfere with the same. 2. The Special Leave Petition stands dismissed 3. Pending application (s) shall stand disposed of.