DELOITTE SHARED SERVICES INDIA LLP (SUCCESSOR OF DELOITTE SHARED SERVICES INDIA PRIVATE LIMITED),MUMBAI vs. DEPUTY COMMISSIONER OF INCOME-TAX CIRCLE - 1(1)(1), MUMBAI, MUMBAI

ITA 5300/MUM/2025Status: DisposedITAT Mumbai18 February 2026AY 2015-16Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that since the assessee owned the e-devices and they were allotted to group entities before the end of the financial year, and user charges were recovered and offered to tax, the 'put to use' condition is met. Therefore, the assessee is entitled to depreciation.

What were the facts?

The assessee claimed depreciation on e-devices which were purchased and allotted to group companies for their use. The Assessing Officer and CIT(A) disallowed the depreciation on the grounds that the devices were not used for the assessee's own business.

What were the issues?

Whether depreciation can be claimed on assets owned by the assessee but used by group entities, when user charges are recovered and offered to tax.

Which sections of the Income-tax Act were involved?

Section 32

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Income Tax Appellate Tribunal, “D” BENCH, MUMBAI

Before: SHRI AMIT SHUKLA, JM & SHRI ARUN KHODPIA, AM

For Appellant: Shri Niraj Sheth, AR, Shri Annavaran Kosuri, Sr. DR
Hearing: 22.12.2025Pronounced: 19.02.2026

Per Arun Khodpia, AM: The captioned appeal of the assessee, preferred against the order of Commissioner of Income Tax (Appeals), NFAC, Delhi (in short “Ld. CIT(A)”), dated 30.06.2025, arises from the order u/s 143(3) of Income Tax Act, 1961 (in short “The Act”) dated 14.12.2017, passed by DCIT-1(1)(1), Mumbai (In short “Ld. AO”), has raised the following ground of appeal: Deloitte Shared Services India LLP

“1:0 Re.: Di

The order continues below.

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