The petitioner  is a partnership firm carrying on the business of manufacture and exports of diamonds . The assessment was completed u/s 143(3) and thereafter reopening was done for alleged bogus purchases . The assessment was done by making GP additions . Thereafter the  reassessment notice was issued again for alleged accommodation entries . On writ allowing the petition the Court held that      the omission of the AO to make an assertion in the reasons that there was a failure to disclose fully and truly all material facts necessary for the assessment is sufficient to set aside the reassessment notice. Also, a notice issued on change of opinion is bad in law . ( WP No. 2506 of 2019, dt. 12.12.2019) ( AY. 2012-2013)