Against the disposal of objection the assessee filed writ before the High Court.  Allowing the petition the Court held that in the present case, the petitioner had truly and fully disclosed all material facts necessary for the purpose of assessment. They were carefully scrutinized and figures of income as well as deduction were carefully reworked by the Assessing Officer. In fact, in the reasons for reopening, there is not even a whisper as to what was not disclosed. Accordingly this is not a case where the assessment is sought to be reopened on the reasonable belief that income had escaped assessment on account of failure of assessee to disclose truly and fully all material facts that were necessary for computation of income but this is a case wherein the assessment sought to be reopened on account of change of opinion of the Assessing Officer about the manner of computation and deduction under Section 80-IA of the Act. Accordingly the same is not permissible. (AY. 2014-15)