Held that the Assessing Officer, in the original assessment, after considering the reply and relevant details provided by the assessee, had accepted the claim of depreciation by the assessee. For temporary structures, the prescribed rate of depreciation was hundred per cent. Once a structure was categorised as temporary, the depreciation rate provided under appendix I appended to the Income-tax Rules, 1962, is hundred per cent. Once it was accepted that the structures were temporary, no case could be made out that the depreciation allowance claimed was excessive. Explanation 1 and Explanation 2(c)(iv) appended to section 147 of the Act would not be applicable. The Assessing Officer had not stated in the reasons to believe that the assessee had failed to disclose truly and fully all material facts. It was a clear case of change of opinion. The notice and the order disposing of the objections of the assessee were quashed(AY. 2012-13