The CIT(A) failed to appreciate that the claim of deduction of bad debts under section 36(1)(vii), exemption under section 10(23G), deduction under section 35DDA had been considered in the assessment order passed under section 143(3) dated December 29, 2006 and section 147 of the Act does not postulate conferment of power upon the Assessing Officer to initiate reassessment proceedings upon a mere change of opinion as has been held by the Delhi High Court (FB) in the case of CIT v. Kelvinator of India (256 ITR 1) and affirmed by the Supreme Court in 320 ITR 561.