Since common points are involved these appeals are being disposed of together. common issue that arises for consideration is whether reopening of assessments under s. 147(a) of IT Act, 1961 for asst. yrs. 1973-74 and 1974-75 are valid. In original assessments assessee claimed sums of Rs. 74,626 and Rs. 3,63,328 in asst. yrs. 1973-74 and 1974-75 respectively, being difference in exchange rates on deferred payments as expenditure. same was allowed as deduction by ITO in original assessments. Subsequently ITO reopened assessments for these two years under s. 147(a). In reassessment orders made under s. 143(3) r/w s. 147(a) ITO disallowed above amounts in two years on ground that said expenditure is capital expenditure relatable to purchase of machinery. He held that assessee gave no explanation in original proceedings regarding allowance of this expenditure and on account of assessee's failure to explain there was wrong allowance of amounts claimed in original assessment, as result of which income has escaped assessment. Thus in reassessment order, he disallowed above amounts. On appeal, CIT(A) held that ITO at stage of original proceedings had gone through items mentioned in relevant profit and loss account and thought it fit to allow same as revenue expenditure. If assessee has disclosed primary facts it is under no obligation to instruct ITO about inference which he may raise from these facts and when primary facts have been fully and truly disclosed in original proceedings ITO is not entitled on change of opinion to commence proceedings under s. 147(a). Thus he held that action of ITO in initiating proceedings under s. 147(a) on mere change of opinion regarding allowability of impugned expenditure cannot be sustained. Thus he annulled reassessment proceedings under s. 147 (a) for asst. yrs. 1973-74 and 1974-75. Against same Revenue has preferred these appeals. ld. departmental representative submitted that assessee had not disclosed facts fully and truly at time of original assessment proceedings. nature of expenditure has not been explained by assessee. Thus there was failure on part of assessee. He further submitted that expenditure incurred due to difference in exchange rates on deferred payments relates to purchase of machinery which, is capital asset and being capital expenditure, it is not allowable. He submitted that reassessment proceedings for these two years are valid and CIT(A) was wrong in annulling said orders for two years. He placed reliance on few decisions. ld. counsel for assessee submitted that full facts have been disclosed in original assessment proceedings and there was no failure on part of assessee to disclose any material facts. assessments have been reopened only due to change of opinion. assessee has always been contending that extra expenditure incurred due to difference in exchange rates on deferred payments is allowable as revenue expenditure. In years where it was disallowed assessee carried matter in appeal disputing disallowance. He submitted that reassessment proceedings under s. 147(a) are bad in law and CIT(A) was justified in annulling assessments. We have considered rival submissions. In profit and loss account for asst. yr. 1973-74 assessee debited Rs. 74,626 under head "Bank charges". description mentioned therein reads as under: "Bank charges (including Rs. 74,626 due to difference in exchange rates on deferred payments) Rs. 2,53,276". Similarly in profit and loss account for 1974-75 under head bank charges sum of Rs. 3,63,328 was debited and narration was as above mentioned. These are primary facts which are required to be disclosed by t h e assessee and they have been disclosed. It if for ITO to draw necessary inference from same to come to conclusion whether it is allowable as revenue expenditure or not. In original assessment proceedings, ITO has allowed same as revenue expenditure. Subsequently, ITO has reopened assessment only on change of opinion but there is no failure on part of assessee to disclose any material facts fully and truly. In reasons recorded by ITO for reopening assessments for these two years it is stated that expenditure was laid out on capital account and amounts were allowed as revenue expenditure without scrutiny and assessee gave no explanation regarding allowance of this exceptional item of expenditure. ITO does not state in reasons which material fact has not been disclosed by assessee in original assessment proceedings. He merely says that assessee gave no explanation and expenditure has been allowed without scrutiny. We have already pointed out that in profit and loss account impugned expenditure has been debited and it is clearly described that impugned payment was due to difference in exchange rates on deferred payments. It was for ITO to make necessary enquiries whether deferred payment was on capital account or revenue account. So far as assessee is concerned, he has claimed it as revenue expenditure. In some years where it was disallowed as capital expenditure, assessee carried matter in appeal. When assessee has claimed expenditure as revenue expenditure it was for ITO to make necessary enquiries. It is for ITO alone to come to conclusion whether expenditure claimed is allowable as revenue expenditure or not. ITO has not pointed out what material fact has not been fully and truly disclosed by assessee. If ITO had asked for further details in assessment proceedings certainly assessee would have furnished it. Once primary facts are disclosed it is for ITO to draw correct inference and it is not for assessee to tell ITO what inference should be drawn. assessment cannot be reopened on change of opinion. In Calcutta Discount Co. Ltd. vs. ITO, Companies District I, Calcutta and Anr. (1961) 41 ITR 191 (SC) Supreme Court held that it is duty of assessee to disclose fully and truly all primary facts and once all primary facts are disclosed it is for ITO to decide what inferences of facts can be reasonably drawn and what legal inferences have ultimately to be drawn and it is not for assessee to tell ITO what inferences should be drawn. above decision was again followed by Supreme Court in Gemini Leather Stores vs. ITO, B-Ward, Agra & Ors. 1975 CTR (SC) 127: (1975) 100 ITR 1 (SC). It was held therein that ITO cannot take recourse to s. 147(a) to remedy error resulting from his own oversight. In CIT, Gujarat vs. Bhanji Lavji (1971) 79 ITR 582 (SC) Supreme Court held that when primary facts necessary for assessment are fully and truly disclosed to ITO at stage of original assessment proceedings he is not entitled on change of opinion to commence proceedings for reassessment under s. 34(1)(a) of Indian IT Act, 1922. In ITO, I-Ward, Hundi Circle, Calcutta & Ors. vs. Madnani Engineering Works Ltd. (1979) 12 CTR (SC) 144: (1979) 118 ITR 1 (SC) ITO allowed interest paid to creditors on hundi loan as revenue expenditure. Subsequently assessment was reopened on ground that hundi loans were bogus and no interest was paid and it was wrongly allowed. On those facts Supreme Court held that assessee had produced all hundis as also entries in books showing payment of interest and it was for ITO to investigate and determine whether these documents were genuine or not and assessee could not be said to have failed to make true and full disclosure of material facts by not confessing before ITO that hundis and entries in books of account produced by it were bogus. In CIT, Calcutta vs. Burlop Dealers ltd. (1971) 79 ITR 609 (SC) Supreme Court held that where on evidence and materials produced during original assessment proceedings ITO could have reached conclusion other than one which he has reached, proceeding under s. 34(1)(a) of IT Act, 1922 will not lie merely on ground that ITO has raised inference which he may later regard as erroneous. assessee was under no obligation to inform ITO about possible inferences that may be raised against it and it was for ITO to raise such inference and if he had not done so in original assessment income that escaped assessment could not be brought to tax under s. 34(1)(a) of IT Act, 1922. ratio laid down in above cases would squarely apply to instant case. In our view assessee had disclosed primary facts fully and truly. fact that impugned payment was due to difference in exchange rates on deferred payment was disclosed in original assessment proceedings. ITO has not pointed out which material fact has not been disclosed by assessee fully and truly. If ITO had allowed expenditure without making necessary enquiries in original assessment proceedings, he cannot reopen assessments under s. 147(a) due to change of his opinion. In our view reassessment proceedings made under s. 147(a) are not valid and CIT (A) was right in annulling reassessment orders for these two years. decisions relied on by ld. departmental representative have no application to facts of instant case. decision of A.P. High Court in K.C.P. Ltd. vs. ITO, Central Circle, Vijaywada-3 (1984) 146 ITR 284 (AP) does not help Revenue in any way. On other hand it supports assessee. It was held on facts of that case that it is not stated by ITO that any particular material fact was not disclosed by assessee and ITO does not state that non- disclosure on part of assessee lies in not disclosing written down value. Thus this case does not help Revenue. decision of Supreme Court in Indo-Aden Salt Mfg. & Trading Co. P. Ltd. vs. CIT, Bombay (1986) 58 CTR (SC) 9: (1986) 159 ITR 624 (SC) also does not support Revenue's case. That is case where assessee claimed depreciation but assessee failed to disclose what portion consisted of earth work and what portion consisted of masonry work. Depreciation was available only in respect of assets constructed of masonry and not earth work. ITO had allowed depreciation as claimed by assessee. Since there was failure on part of assessee to disclose which portion is masonry and which portion is earth work and as excess depreciation was allowed on account of failure of assessee to disclose facts fully and truly assessment was reopened under s. 147(a). Supreme Court held that assessment was validly reopened. facts in that case are entirely different and it has no application to facts of instant case, Thus we uphold order of CIT(A). In result, appeals fail and are dismissed. *** INCOME TAX OFFICER v. A.P. PAPER MILLS LTD.