Allowing the petition the Court held that there was not even a whisper that there was failure on part of assessee to disclose fully and truly all material facts. In computation of income filed along with profit and loss account, assessee had disclosed business income and had deducted from business income gain on Foreign Exchange Fluctuation and had furnished all details relating to same and it was admitted that notice to re-open came to be issued in view of audit objection there had not been non-disclosure of any material fact but only change of opinion. Court held that   since, reasons for re-opening assessment was not that of Assessing Officer alone issuing notice but he had acted merely on dictates of another person for issuing notice, i.e., audit department. Accordingly the notice and order disposing the objection is  quashed.  (AY. 2013-14)