Dismissing the appeal the Court held that  once a query had been raised with regard to a particular issue during the regular assessment proceedings it must follow that the Assessing Officer had applied his mind and taken a view in the matter as reflected in the assessment order. A query was raised by the Assessing Officer in the original assessment in respect of the waiver of loan on account of the one time settlement with the bank and the assessee had filed a detailed submission as to why the principal amount waived by the bank on account of the one time settlement was not taxable. Reassessment on a change of opinion was impermissible. No question of law arose.  Referred , CIT v. Kelvinator of India Ltd ( 2010 ) 320 ITR 561 ( SC) , followed  Aroni Commercials Ltd v.ACIT ( 2014) 367 ITR 405 ( Bom) (HC), Marico Ltd v .ACIT ( 2020) 425 ITR 177 ( Bom) ( HC)  ( AY.2007-08)