Dismissing the appeal of the revenue the Court held that details were placed before the AO, at the time of original assessment and therefore, it is not possible to infer that the AO had not at all applied his mind. The initiation of the reassessment proceedings on account of change of opinion’ is not permissible in law as the AO had examined all the relevant material furnished by the assessee and had accepted the claim of the assessee. Followed CIT v. Kelvinator of India Ltd (2010) 320 ITR 561 (SC).  (AY. 2005-06)