Assessee-company was engaged in business of port facility In previous assessment years, assessee received compensation in respect of damages to wharf and same was partly shown in capital account and balance in revenue account. In relevant assessment year, assessee claimed its entire income as deduction under section 80-IA.During scrutiny, Assessing Officer asked for information related to income qualifying for deduction and after considering relevant information disclosed by assessee allowed claim.Subsequently, a reopening notice was issued by Assessing Officer on ground that assessee had credited its profit and loss account with respect to compensation received for loss of profit and damages to wharf.On writ the Court held that the financial statements mentioned amount received as compensation towards damages to wharf the reasons to believe escapement of income revealed that reopening of assessment was based on examination of financial statements furnished by assessee. Since Assessing Officer had all primary facts to make necessary inquiry and had relied on financial statements and other documents furnished by assessee itself for reason to believe that income had escaped assessment, reopening was on basis of change of opinion hence reassessment notice and order disposing the objection is quashed.  (AY. 2013-14)