Allowing the petition the Court held that  there had been a full and true disclosure of the material facts by the assessee in the return of income  and the reopening of the assessment was on change of opinion to take a different view relying on the same set of documents. Change in opinion cannot construe reason to believe. During the assessment proceedings the Assessing Officer had started from the income as returned by the assessee which included self-disallowances on account of advance doubtful of recovery and provision of non-moving inventory. Reassessment notice and order rejecting  objections was  quashed. (AY-2005-06)