The assessment of the assessee was completed u/s 143(3) of the Act .  After a period of four years the notice under S. 148 of the  Act was issued  to reopen the assessment .  The assessee filed a writ petition against such notice. During the pendency of the writ petition, another notice under section 148 was issued to reopen the assessment for the assessment year 2009-10. The reasons recorded were that the activity carried out by the assessee did not amount to manufacture and hence the claim made by the assessee under S.  80IB(4) was to be disallowed. It was the contention of the assessee that under the Central Excise Act, 1944 the Excise Department had accepted that the activity undertaken by it amounted to manufacture and refunded the amounts payable for the respective financial years. The Deputy Commissioner rejected the objections raised by the assessee to the reopening of the assessments. On writ the Court held that  whether the activity undertaken by the assessee amounted to manufacture or not, was deliberated upon before the respective assessment orders were passed. The assessee was specifically asked to explain the process of manufacture for claiming the benefit of deduction under S.  80IB , and the assessee had furnished all the details. It was only thereafter that the assessments were completed for the respective assessment years. The Department had not denied that the assessee had truly and fully disclosed all the materials that were required for completing the assessments. Therefore, a change of opinion based on the report of the Asst.Commissioner, Jammu under S.  131 could not amount to failure on the part of an assessee to truly and fully disclose information or documents required for the purpose of completing the assessments. The reopening of the assessments to deny the deductions under S.  80IB was without jurisdiction.( AY.2009-10, 2010-11)