Assessing Officer issued a reopening notice claiming that assessee-trust was not entitled to claim carry forward and set-off of deficit after claiming exemption under section 11(1) since as per provision of section 11(1)(a) assessee could carry forward deficit of earlier years and set it off against surplus of subsequent years. On writ the Court held that there was no failure on part of assessee to disclose material fact, impugned notice issued under section 148 on mere change of opinion. Notice and order disposing the objection was quashed (AY. 2008-09)