Allowing the petition the Court held that the reopening of the assessments  was merely on a change of opinion and there was no failure on the part of the assessee to truly and fully disclose all the material facts that were required for assessment by the Assessing Officer. The Assistant Commissioner in the original assessment order had merely disallowed the bare boat charter cum demise hire charges perhaps on account of the order passed by the Income-tax Officer (IT). There was no failure by the assessee to truly and fully disclose all information required for assessment. The reassessment order was quashed. (AY. 2004-05, 2005-06)