On writ the Court held  that  as per proviso to section 147 of the Act, as the assessee had disclosed truly and fully all material facts during the regular assessment, no notice could have been issued under section 148 of the Act. Moreover, in view of scrutiny of the issue of disallowance under section 14A of the Act read with rule 8D of the Rules during the regular assessment proceedings, reopening on the same issue would amount to mere change of opinion of the Assessing Officer. The notice was not valid.(AY.  2014-15)