Held, that there was no failure on the part of the petitioner to disclose fully and truly all material facts necessary for its assessment. Even from the record, it was evident that in the statement of income minimum alternate tax credit details were filed. No details or further inquiry was made on the claim. Having accepted the claim in the absence of any other reason, reassessment on the very issue was a change of opinion. The notice of reassessment was not valid.(AY. 2012-13)