Allowing the appeal the Tribunal held that the assessee had filed before the Assessing Officer a detailed note on exemption claimed under sections 54F and 54EC along with supporting documents. From the purchase agreement of the residential property and its annexures, which were filed before the Assessing Officer during the course of original assessment proceedings, it was evident that the assessee had purchased a residential property comprising a house of 6700 square feet and another house of 400 square feet along with the land appurtenant thereto and claimed deduction under section 54F against the sale of shares held long-term. The assessee had disclosed all the primary facts necessary for assessment of its case to the Assessing Officer. Thus a mere change of opinion by the Assessing Officer could not be a ground for reassessment. The reopening of the assessment under section 147 by the Assessing Officer was liable to be quashed. (AY.2008-09)