High Court held that the notice of reassessment was not valid because the Assessing Officer had all material facts before him when he made the original assessment, there was a specific averment in the petition that the assessee had truly and fully disclosed all material facts at the time of the original assessment which the respondents had not rebutted, this was not a case where the assessment was sought to be reopened on the reasonable belief that income had escaped assessment on account of failure of the assessee to disclose truly and fully all material facts that were necessary for computation of income but a case where the assessment was sought to be reopened on account of change of opinion of the Assessing Officer and this was not permissible in view of the proviso to section 147 of the Income-tax Act, 1961. SLP of Revenue is dismissed.  (AY.2015-16)