Dismissing the appeal of the revenue the Court held that notice to reopen assessment had been issued beyond four years from end of relevant assessment year and, there was no failure on part of assessee to disclose fully and truly all material facts at time of assessment. Accordingly the Tribunal rightly held that reassessment notice is issued  due to change of opinion. Order of Tribunal is affirmed. (ITA No. 1357 of 2016 dt 11-1-2019)