Allowing the petition, the Court held that there was no failure on part of assessee to disclose fully and truly all material facts as all relevant facts had not only been disclosed, but had also been considered by Assessing Officer while considering claim of deduction under section 35(2AB) in order of assessment, reopening of assessment being a mere change of opinion was not justified. Re assessment notice issued and order disposing the objection was quashed. (AY. 2015-16)