Reassessment under Section 147 invalid when taxpayer disclosed full primary facts; change of opinion and concurrent notices void

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....The HC held that reopening under Section 147 is unsustainable where the assessee had divulged full and true primary facts in the return; the impugned reassessment lacked statutory foundation and therefore contravened Section 147. A mere change of opinion by the AO cannot constitute a valid reason to reopen assessment. Issuance of a second notice while an earlier notice subsisted was declared invalid, rendering consequent proceedings a nullity. In view of these conclusions the writ petition was allowed and the reassessment proceedings and consequential orders were quashed.....