The assessment was completed under section 143(3) of the Act. Thereafter, a notice was issued under section 148 of the Act within a period of four years to reopen the assessment. The Assessing Officer in the reassessment proceedings disallowed a sum of Rs. 6.5 crore which was in the nature of provision made for compensation payable with respect to disputes with certain parties. High Court observed that the factual finding that the amount of compensation was recorded to be paid as and when settled by the Civil Courts and the amount not paid was returned back as part of other income was undisputed and uncontroverted by the Revenue. Accordingly, the High Court held that the provision of Rs. 6.5 crore was allowable as deduction. High Court further held that the dis-allowance of the claim of compensation was based on record that was already with the Assessing Officer at the time of the proceedings under section 143 (3) of the Act and that there was no new or fresh tangible material that had been brought on record. High Court held that the Assessing Officer had viewed the same material from a different angle of perception which was nothing but a case of change of opinion which could not be permitted. (AY. 2008-09)