The AO sought to reopen the assessment proceedings on the ground that considering the nature of business activities of the assessee, it was not entitled to the benefits of Chapter XIIG of the Act. Held that since the AO had already perused the nature of business of the assessee in the original assessment proceedings and the same was explained sufficiently by the assessee, reopening on the same issue within 4 years is not permissible as there was no failure on the part of the assessee to disclose truly and fully all material facts. Further held that since there was no new material on record on the basis of which the proceedings were sought to be reopened, it was also a case of change of opinion. The proceedings were to be quashed. (AY. 2011-12)