The petitioner filed the writ against the disposal of objection against reassessment notice. Allowing the petition the Court held that there was no failure to disclose the material facts. The Court held that the assessing officer has the power to reopen the assessment provided there is tangible material to conclude that there is escapement of income from assessment and further, the reasons must have a live link with the formation of the belief. A mere change in opinion cannot be a reason to reopen. This decision holds that there is a conceptual difference between power to review and power to reassess and that the assessing officer has no power to simply review (AY. 2010-11)