AO issued a notice under section 148 so as to reopen the assessment after expiry of four years from the end of relevant assessment year so as to disallow exemption claimed by assessee under sections 54 and 54F. Assessee challenged the notice by way of writ petition taking plea of proviso to section 147. Assessee, during original assessment proceedings, had furnished substantive information and answered specific queries raised by AO who had clearly applied his mind while computing capital gains and exemption under sections 54 and 54F after forming a view. Hence, it was held that this was a clear case of change of opinion which was impermissible in law and thus there was no failure on the part of the assessee to disclose fully and truly all material facts necessary for the assessment. Therefore, a reassessment notice and order disposing the objection is  set aside.(AY. 2015-16)