The assessment was completed u/s 143(3) of the Act. Notice for reassessment was issued on the ground that non consideration of exchange rate had benefited the assessee to the extent of Rs.33,80,77,707/-which has not been offered by the assessee to tax. Hence, there is an escapement of income. The objection of the assessee was dismissed. On writ allowing the petition the Court held that hat these figures were all available before the Assessing Officer, who has considered the same and after applying his mind, passed the original assessment order. Therefore the reason to reopen on change of opinion. The Assessing Officer had all materials facts before him when he made the original assessment. When the primary facts necessary for assessment are fully and truly disclosed, the Assessing Officer is not entitled on change of opinion to commence proceedings for reassessment. Even if the Assessing Officer, who passed the assessment order, may have raised too many legal inferences from the facts disclosed, on that account the Assessing Officer, who has decided to reopen assessment, is not competent to reopen assessment proceedings. it would not be open to reopen the assessment based on the very same material with a view to take another view. Accordingly the reassessment notice and order disposing the objection was quashed.  (AY. 2012-13)