Allowing the petition the Court held that, where during original scrutiny under section 143(3) the assessee had fully disclosed the receipt of dividend from a trust and the claim of investment allowance and the Assessing Officer had examined the same, reopening after four years based on a mere bald allegation of failure to disclose material facts amounted to a change of opinion. Notice under section 148 and the order rejecting objections were quashed. (AY. 2013-14, 2014-15.)