Assessee had created certain provisions in respect of technical fees payable in some earlier years. As tax was not deducted during those earlier years, the provisions were not allowed as deduction in those years. During the year under consideration, the assessee reversed the provisions. The Assessing Officer, in the course of original assessment proceedings, accepted the assessee’s submission that as the original provision was not allowed as a deduction, reversal of the same could not be taxed again in the year under consideration. Assessing Officer thereafter issued a notice under section 148 and in the reassessment order assessed to tax the amounts of provisions which were reversed during the year. High Court held that the reassessment was initiated on ‘change of opinion’ as the Assessing Officer had stated that the issue was ‘inadvertently’ allowed in the original assessment proceedings without verifying the reversal of provisions. High Court held that the reassessment proceedings were invalid as the same was contrary to the law laid down by the Supreme Court in CIT v. Kelvinator of India Ltd. (2010)320 ITR 561(SC).  (AY.  2008 – 09)