Akil Abdul Hamid Kureshi, J.

1. The petitioner has challenged a notice dated 30.3.2012 issued by the respondent Assessing Officer to reopen the petitioner's assessment for the assessment year 2005-2006.

2. Brief facts are as under. The petitioner is a company registered under the Companies Act. For the assessment year 2005-2006, the petitioner had filed return of income on 31.10.2005 declaring total income of Rs. 57.73 lacs. Such return was taken in scrutiny by the Assessing Officer. He passed the order of assessment on 27.12.2007 computing total income of Rs. 5.86 crores (rounded off). To reopen such assessment, the Assessing Officer issued notice dated 11.1.2011. Briefly stated, the reasons recorded for issuing such notice were that the assessee was holding certain shares as stock-in-trade. On 1.4.2004, the assessee transferred such shares from stock-in-trade to investment. This was done at the cost price and not the market value. According to the Assessing Officer, the difference between the cost of acquisition of shares and the market value on the date of conversi