Allowing the petition the Court held that  on the facts, there was no failure on the part of the assessee to disclose any material facts necessary for the assessment year   Audited accounts were filed during the course of assessment proceedings. In the assessment order, the Assessing Officer had recorded that the details called for had been furnished and discussed  The reopening of assessment  was on change of opinion which did not constitute justification or reason to believe that income had escaped assessment.(AY.2013-14)