Held that there is not a single averment about the failure on the part of the assessee to disclose all the material facts at the time of original assessment proceedings. There is no infirmity in the detailed findings of the CIT(A) in quashing the reassessment proceedings on the ground of change of opinion as well as on the ground of limitation as per the first proviso to s. 147 in absence of any allegation against the assessee of failure at its end and accordingly the reopening in the case was not in accordance with law (AY.2008-09,  2009-10)