Assessee company was engaged in business of marketing of animal health products. Assessing Officer issued a reopening notice on ground that expenditure incurred by assessee towards cost of purchase of samples for distribution under head ‘advertisement and sales promotion’ was in violation of provisions of Indian Medical Council (Professional Conduct, Etiquette and Ethics) Regulations, 2022 and, thus, same was not admissible under section 37(1) being expenses prohibited by law. On writ the Court held that  it was evident from affidavit-in-reply that Assessing Officer had all material facts related to such expenses before him when he made original assessment.  Apart from it, specific query in respect of expenditure in question was raised at time of original assessment and same was also replied by assessee-There was no failure on part of assessee to truly and fully disclose all material facts necessary for purpose of assessment which were carefully scrutinized by Assessing Officer during original assessment. In reasons for reopening, there was not even a whisper as to what was not disclosed by assessee for which assessment was sought to be reopened. Reassessment notice was quashed on the ground of change of opinion.  (AY. 2014-15)