Dismissing the petition the Court held that the issues involved questions which related to accounts and had to be decided by the original authority. Mere filing of the annexure by the assessee in response to the notice during scrutiny assessment by itself might or might not have been sufficient to conclude that there was full and true disclosure by the assessee if the information furnished was neither complete nor true. To ascertain whether it was a mere change of opinion or not, it had to be first established that there was true and full disclosure which could be demonstrated by the assessee only in a proceeding before the Assistant Commissioner and not under article 226 of the Constitution of India as the scope of judicial review was limited and it was not possible to conduct a roving enquiry on facts and accounts. The assessee was to participate in the proceedings before the Assistant Commissioner. (AY. 2003-04)