Tribunal held that the reasons recorded nowhere showed that there was any allegation of failure to disclose any material facts . The very same fact was examined by  the Assessing Officer in the first round of  reassessment proceedings. Therefore, issue of  notice again on the same set of facts  facts amounted to change of  opinion. Merely using the expression “Failure on  the part of  the assessee to disclose fully and truly all material facts”  was not enough. The reason must specify the nature of  default or  failure on the part of  the assessee. The reassessment proceedings is held to be  illegal and void ab  initio(AY.2012-13).