Allowing the petition the Court held that  reassessment notice is issued after the expiry of four years, the only reason for initiating reassessment proceedings by notice dated March 30, 2019, was that depreciation was allowable only at 30 percent and not at 60 percent. This change of opinion could not be made a ground for reassessment. The AO, during the course of original assessment, had accepted the return and treated certain expenses as revenue as these were incurred only to facilitate the business of the assessee who was engaged in the business of advertising and marketing communications. There was no failure to disclose material facts necessary for assessment. The notice and order disposing the objection is quashed.(AY. 2012-13)