Allowing the petition the Court held that  that it was evident that during the original assessment proceedings a specific query was raised by the Assessing Officer with respect to section 14A of the Income-tax Act, 1961, and the assessee appropriately replied. The reply was accepted at the relevant point of time. The very same issue was sought to be raised for the purpose of reopening the assessment. This was otherwise not permissible in law on mere change of opinion. It could not also be said that there was any failure on the part of the assessee to fully and truly disclose all the material facts. The notice of reassessment was not valid. (AY.2012-13)