The Assessing Officer restricts himself only to deal with those issues where he does not agree with the Assessee's submission and gives reasons for it. Otherwise, it would be impossible to complete all the assessments within time limit available. Thus, the Court held that once a query is raised during Assessment Proceedings and the Assessee has responded to the query, to the satisfaction of the Assessing Officer, then there has been due consideration of the same. Therefore, issuing of the re-opening notice on the same facts which were considered earlier, clearly amounts to change of opinion. Thus, without jurisdiction.