Allowing the petition the Court held that the notice of reassessment was issued after four years on the basis of a technical mistake of the auditor of failing to mention the date in form 3CD at the time of submitting the report. At the relevant time, the Assessing Officer had examined the issue at length and did not disallow the depreciation claim. Reassessment notice was quashed on the ground of change of opinion. (AY.2012-13)