The  reassessment notice was issued under section 148 of the Act for denying the exemption under section  54F of the Act  and no information was furnished to the assessee. On writ allowing the petition the Court held that the  assessee having fully and truly disclosed all material facts necessary for purpose of assessment, reopening of assessment was clearly on basis of a change of opinion and that too without any new tangible information.  Accordingly the notice and assessment order is quashed and set aside.  (AY. 2015-16)