Allowing the petition, the Court held that during course of original assessment proceedings assessee produced scrip-wise details of opening stock, purchases and sales as well as closing stock along with documentary evidence in support thereof and Assessing Officer requested the assessee to submit Form No. 10DB duly certified and reconciled with audited account. There was no failure on part of assessee to disclose any material facts fully and truly during regular assessment proceedings and, thus, reassessment proceedings based on change of opinion was not sustainable. Reassessment notice and order disposing the objection was quashed. (AY. 2013-14)