Allowing the petition  the Court held that during scrutiny assessment, AO had raised queries and assessee had made detail submissions providing materials on allowability of deduction underS 80IB(10) of the Act  and thereafter the claim was allowed .  AO sought to reopen assessment on ground that income had escaped assessment as there was no full and true disclosures on part of assessee . Court held that  the assessee having produced full accounts and provided full details including built-up area of flats sold, reopening of assessment on basis of same material would be mere change of opinion and hence not permissible.  (AY. 2011-12)