Where the assessment of a firm was completed under section 143(3) and the record, including the partnership deed and Form No. 3CD, showed a Hindu Undivided Family (HUF) as a partner, a subsequent reopening of the assessment was initiated after four years from the end of the relevant assessment year. The Assessing Officer’s reason for reopening was that a HUF cannot legally be a partner and, therefore, the conditions of section 184 were not complied with. The High Court held that this was a clear case of change of opinion, as all material facts were fully and truly disclosed by the assessee and were on record during the original assessment. As there was no failure on the part of the assessee to disclose material facts, the jurisdictional condition for reopening an assessment beyond four years was not satisfied. Accordingly, the notice for reassessment was quashed. (AY. 2012-13)