Held that  there was no hint in the reasons to reopen that there had been a failure by the assessee to truly and fully disclose material facts. The reason itself indicated that everything had been disclosed because it stated that on perusal of the records that the assessee was allowed the deduction under section 32AC of the Act. Moreover, during the course of assessment proceedings, the assessee was told to provide a detailed break-up of various plants and machinery installed and commissioned pursuant to section 32AC of the Act. The assessee provided the details and also forwarded the details which were called for during the hearing held on September 22, 2016, of installation date item-wise in respect of the plant. In the order disposing of the objections, there was no denial of the fact that these materials were made available or these details were called for during the assessment proceedings. The only explanation was that these had not been discussed in the assessment order. The Assessing Officer himself had replied to the audit objection raised denying that there was any escapement of income. In the letter dated March 4, 2021, it was stated audit objection/observation was not acceptable to the Department. When the primary facts necessary for the assessment were fully and truly disclosed, the Assessing Officer was not entitled on change of opinion to commence proceedings for reassessment. Reassessment  notice and order disposing the objection is quashed. (AY.2014-15)