“additional depreciation”

DepreciationSection 32(1)(iia)Section 32(1)(iia)604 judgments

DCM SHRIRAM INDUSTRIS LTD,NEW DELHI vs. DCIT CIRCLE-7(1), NEW DELHI

In the result, the appeal filed by the assessee is allowed in above terms

ITA 2166/DEL/2022[2018-19]Status: DisposedITAT Delhi18 Mar 2026AY 2018-19

Bench: Shri Challa Nagemdra Prasad & Shri S. Rifaur Rahman

Section 115JSection 143(3)Section 144C(10)Section 14ASection 80Section 92C

being an exemption provision not being liable to be compared with Section 32(1)(ii-a) and which was concerned with a claim for additional depreciation. Regard must also be had to the fact that Section 10B(1) is essentially concerned with the grant of exemptions to newly established hundred

THE BANK OF TOKYO MITSUBISHI UFJ,NEW DELHI vs. DCIT, CIRCLE- 3(1)(1), INTERNATIONAL TAXATION, NEW DELHI

In the result, the appeal of the assessee is partly allowed

ITA 7212/DEL/2017[2013-14]Status: DisposedITAT Delhi13 Mar 2026AY 2013-14

Section 143(2)Section 143(3)Section 144Section 44C

that Section to mean that the total income\ncomputed in accordance with the provisions of this act. It excludes certain allowances\nsuch as depreciation, additional depreciation and certain expenditure covered u/s 36\n(1) (ix) of the act. It also prohibits allowance under sections 72, 73, 74 and 74A with

ASSISTANT COMMISSIONER OF INCOME TAX, AAYKAR BHAWAN, KOLHAPUR vs. KOLHAPUR ZILLA SAHAKARI DUDH UTPADAK SANGH LIMITED, KOLHAPUR

In the result, the appeal of the Revenue is partly allowed for statistical purposes

ITA 300/PUN/2024[2018-19]Status: DisposedITAT Pune11 Mar 2026AY 2018-19

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.300/Pun/2024 Assessment Year : 2018-19 Acit, Kolhapur Vs. Kolhapur Zilla Sahakari Dudh Utpadak Sangh Limited, B-1, Midc, Gokul Shirgaon, Kolhapur – 416234 Maharashtra Pan : Aaaak0230D Appellant Respondent

For Appellant: Shri Sushant PhadnisFor Respondent: Shri Amol Khairnar

Section 143(3)

facts and circumstances of the case the Id.CIT(A) erred in deleting the addition of Rs.9,15,34,305/- made on account of additional depreciation and not appreciating the fact that the claim of additional depreciation had been disallowed by Ld.CIT(A), Kolhapur in assessee's own case ... this ground, Revenue has referred to the claim of additional depreciation denied by ld. Assessing Officer. We note that during the year under consideration assessee has purchased new machineries claiming to have being utilised for 4 Kolhapur Zilla Sahakari Dudh Utpadak Sangh Ltd. increasing the capacity for production

DY. COMMISSIONER OF INCOME TAX, CIRCLE-1, THANE, WAGLE INDUSTRIAL ESTATE, THANE WEST vs. M M PLASTOWARE INDIA PRIVATE LIMITED, THANE

In the result, appeal of the Revenue is dismissed and cross objection of the assessee is allowed

ITA 133/MUM/2025[2016-17]Status: DisposedITAT Mumbai10 Mar 2026AY 2016-17

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2016-17 Deputy Commissioner Of M M Plastoware India Private Income Tax, Circle-1, Thane Limited Gala No. 10-15, Arihant Darshan, Vs. 90 Feet Road, Bhayander West, Thane – 101101. (Pan: Aahcm2568D) (Appellant) (Respondent) C.O. No. 120/Mum/2025 Assessment Year: 2016-17 M M Plastoware India Private Deputy Commissioner Of Income Limited Tax, Circle-1, Thane Gala No. 10-15, Arihant Darshan, 90 Feet Road, Vs. Bhayander West, Thane – 101101. (Pan: Aahcm2568D) (Appellant) (Respondent) Present For: Assessee : Shri Lalit Munoyat, Ca Revenue : Shri Bhagirath Ramawat, Sr. Dr Date Of Hearing : 22.12.2025 Date Of Pronouncement : 10.03.2026 O R D E R Per Girish Agrawal:

For Appellant: Shri Lalit Munoyat, CAFor Respondent: Shri Bhagirath Ramawat, Sr. DR

Section 143(3)Section 254Section 32(1)(ila)

ambit of perversity. 2. On the facts and in circumstances of the case, while deciding the Ground of Appeal No.2 for allowing unclaimed additional depreciation u/s.32(1)(ila) of 20% on the new asset acquired during FY 2015-16, the CIT(A) erred in Para No.4.2.4 by allowing the appeal ... addition to the depreciation allowed by the AO 3. Total allowed by the CIT(A)- Normal 2,16,31,266 4. Additional Depreciation allowed by the CIT(A) 97,23,986 5. Total depreciation allowable as per CIT(A) 3,13,55,252 Order 6. Depreciation actually allowed

DEPUTY COMMISSIONER OF INCOME TAX-2(2)(1), MUMBAI, AAYAKAR BHAVAN, CHURCHGATE vs. MUMBAI INTERNATIONAL AIRPORT LIMITED, MUMBAI

ITA 7035/MUM/2025[2014-15]Status: DisposedITAT Mumbai09 Mar 2026AY 2014-15

Section 14ASection 250Section 28Section 32(1)(ii)Section 35D

nthese assets satisfy the functional test and ought to be classified\nunder the “plant and machinery” block, thereby eligible for\ndepreciation at 15%. The additional depreciation claimed\nrepresented only the differential 5%, arising due to reclassification\nof the assets from building to plant and machinery.\n62. The assessee further explained

MUMBAI INTERNATIONAL AIRPORT LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 2(2)(1), MUMBAI, MUMBAI

The appeal of the assessee is allowed for statistical purposes, whereas the appeal of the Revenue is dismissed

ITA 6692/MUM/2025[2014-15]Status: DisposedITAT Mumbai09 Mar 2026AY 2014-15

Bench: Shri Saktijit Dey & Shri Makarand V Mahadeokara.Y:2014-15 Mumbai International Vs. Dcit, Circle – 2(2)(1) Airport Ltd., Aayakar Bhavan, Mk Road 1St Floor, Terminal-1B, New Marine Lines, Mumbai – Chhatrpati Shivaji 400020. International Airport, Santacruz (E), Mumbai – 400099. Pan/Gir No. Aaecm6285C (Applicant) (Respondent) A.Y:2014-15 Dcit, Circle – 2(2)(1) Vs. Mumbai International Aayakar Bhavan, Mk Road Airport Ltd., New Marine Lines, Mumbai – 1St Floor, Terminal-1B, 400020. Chhatrpati Shivaji International Airport, Santacruz (E), Mumbai – 400099. Pan/Gir No. Aaecm6285C (Applicant) (Respondent) Assessee By Shri Saurabha Soparkar Virtually Appeared Revenue By Shri Annavaram Kosuri, Sr. Ar Date Of Hearing 25.02.2026 Date Of Pronouncement 09.03.2026 आदेश / Order Per Makarand V Mahadeokar, Am: These Cross Appeals Are Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals) Under Section 250 Of The Mumbai International Airport Ltd., Mumbai Income-Tax Act, 1961 Dated 05.08.2025 In The Case Of The Assessee For Assessment Year 2014–15. The Assessment In The Present Case Was Originally Completed By The Assessing Officer Under Section 143(3) Of The Act Vide Order Dated 30.12.2017. Since The Issues Involved In The Appeals Of The Revenue As Well As The Assessee Arise Out Of The Same Appellate Order Of The Ld. Cit(A), These Appeals Were Heard Together & Are Being Disposed Of By Way Of This Common Order For The Sake Of Convenience & Brevity.

Section 143(3)Section 14ASection 250Section 28Section 32(1)(ii)Section 35D

these assets satisfy the functional test and ought to be classified under the “plant and machinery” block, thereby eligible for depreciation at 15%. The additional depreciation claimed represented only the differential 5%, arising due to reclassification of the assets from building to plant and machinery. 62. The assessee further explained

PLEZER DIGITAL PRESS,SURAT vs. ITO, WARD-3(3)(1), SURAT

In the result, the appeal filed by the Assessee is treated as allowed for statistical purpose

ITA 1155/SRT/2025[2023-24]Status: DisposedITAT Surat03 Mar 2026AY 2023-24

Bench: Ld. Cit(A). However Not Looking Into The Email Address Wherein The Hearing Notices Were Sent By Cit(A) On 17-07-2025, 31- 07-2025 & 02-09-2025, Thereby Dismissed The Appeal For Non- Prosecution. However Ld. Cit(A) Dismissed The Appeal On Merits Also As No Documentary Evidences Filed Before Him.

Section 143(3)Section 68

total income of Rs.12,95,450/-. The return was taken for scrutiny assessment and the assessing officer made addition on wrong claim of depreciation, additional depreciation and unsecured loan of Rs.15,00,000/-. 3. Aggrieved against the assessment order, assessee filed an appeal before Ld. CIT(A). However not looking

PLASCOM INDUSTRIES LLP,KOLKATA vs. THE INCOME TAX OFFICER, WARD-1(3), GUWAHATI

In the result, appeal of the assessee is allowed

ITA 280/GTY/2025[2023-24]Status: DisposedITAT Guwahati02 Mar 2026AY 2023-24

Bench: SHRI GEORGE MATHAN, JUDICIAL MEMBER SHRI LAXMI PRASAD SAHU (Accountant Member)

For Appellant: S.M. Surana, AdvocateFor Respondent: Sanjay Jha, JCIT

Section 133(6)Section 142(1)Section 250Section 801ESection 801E(3)Section 801E(4)Section 801E(5)Section 801E(6)Section 80I

course of assessment proceeding the Ld. AO asked for details of purchase of plant and machinery since the assessee claimed depreciation as well as additional depreciation as can be seen from the computation of income vide paper book page 1 wherein the assessee claimed depreciation ... including additional depreciation of Rs.1,16,97,047/- vide copy of return at paper book page27) and business loss of Rs 5,97,371/. The assessee duly filed the same. These were required by the Ld. AO because the assessee claimed additional depreciation on all the machineries installed during

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 2 1 1 AHMEDABAD, AHMEDABAD vs. SABARKANTHA DISTRICT CO-OPERATIVE MILK PRODUCERS UNION LIMITED, AHMEDABAD

The appeal of the Revenue is dismissed

ITA 2522/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad27 Feb 2026AY 2015-16

Bench: Shri Sanjay Garg (Judicial Member), Smt. Annapurna Gupta (Accountant Member)

Section 143(3)Section 32Section 80P(2)(d)

erred both on facts and in law in treating the Finance Act, 2015 amendment as retrospective and in allowing the carry forward of addition depreciation of Rs. 1,09,44,773/-subsequent assessment year?" to a 3. "Whether on the facts and in the circumstances of the case ... justified in allowing depreciation and additional depreciation claimed on CANs and Equipments amounting to Rs. 1,20,85,228/- when it is clear that Milk Cans and Equipment do not qualify as 'Plant and Machinery' for the purpose of additional depreciation u/s 32 of the Act?" 4." The appellant craves

VIMALA JAYANTILAL PUROHIT,MUMBAI vs. INCOME TAX OFFICER CIRCLE 17(1), MUMBAI

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 7063/MUM/2025[2023-24]Status: DisposedITAT Mumbai27 Feb 2026AY 2023-24

Section 143(3)Section 250Section 32

assessed at the income determined\nby the Ld. AO.\n2. Disallowance of Additional Usage Period Depreciation Machinery That the Ld.\nAO erred in disallowing additional depreciation of Rs 29,07,161/- on the ground\nthat the machinery was not put to use for more than 182 days, without\nappreciating ... business nature, facts and relevant explanations/evidences\nfurnished. The appellant prays that the additional depreciation be allowed as\nclaimed.\n1\nCalculation of Depreciation.\nSany Rig SR235-C10 and Machinery Tools: Though the assets were mentioned\nunder \">182 days,\" How ever while calculating the Depreciation We have\ncharged Depreciation and additional depreciation

VIRCHOW PETROCHEMICAL PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-8(1), HYDERABAD

ITA 1191/HYD/2025[2015-16]Status: DisposedITAT Hyderabad26 Feb 2026AY 2015-16

For Appellant: \nShri M.V. Prasad, CAFor Respondent: \nMs. U. Mini Chandran

Section 143(3)Section 147Section 148Section 250

proviso” to section 147 of the Act, submitted that the assessee's\nclaim for depreciation/additional depreciation on solar power plant, (i.e.,\n80% depreciation + 20% additional depreciation) was clearly discernible\nfrom the depreciation chart filed by the assessee company under per the\nIncome Tax Act, 1961 for the subject year, along ... observed that the\nassessee has claimed 100% depreciation of Rs. 7,34,14,979/- on solar\npower plant (80% on power plant -20% additional depreciation) in A.Y.\n2015-16. However, the assessee has not received and offered any\nincome from sale of power from the above power generation plant

FRANKLIN TEMPLETON INTERNATIONAL SERVICES (INDIA) P.LTD,MUMBAI vs. DCIT CIR 6(3)(1), MUMBAI

ITA 1495/MUM/2015[2010-11]Status: DisposedITAT Mumbai20 Feb 2026AY 2010-11

Section 133(6)Section 92D

passed after 31 December 2011 (time limit as per Section 153 of\nthe Act) is time barred and liable to be quashed;\nClaim for additional depreciation\n1. The AO erred in not allowing depreciation of Rs. 7,17,193 on the\nwritten down value of assets being items included ... passed after 31 December 2012 (time limit as per Section 153 of\nthe Act) is time barred and liable to be quashed;\nClaim for additional depreciation - The ground was adjudicated\nbased on earlier year's order (Relevant pages attached at Page\n108)\n1. The AO erred in not allowing depreciation

FRANKLIN TEMPLETON INTERNATIONAL SERVICES (INDIA) P.LTD,MUMBAI vs. DCIT CIR 3(1), MUMBAI

In the result, appeals filed by the assessee stands partly allowed

ITA 2047/MUM/2014[2009-10]Status: DisposedITAT Mumbai20 Feb 2026AY 2009-10

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 133(6)Section 92D

passed after 31 December 2011 (time limit as per Section 153 of the Act) is time barred and liable to be quashed; Claim for additional depreciation 1. The AO erred in not allowing depreciation of Rs. 7,17,193 on the written down value of assets being items included ... passed after 31 December 2012 (time limit as per Section 153 of the Act) is time barred and liable to be quashed; Claim for additional depreciation - The ground was adjudicated based on earlier year's order (Relevant pages attached at Page 108) 1. The AO erred in not allowing depreciation

G.C.T.ALUMNI ASSOCIATION,COIMBATORE vs. ACIT, EXEMPTIONS,, COIMBATORE

The appeal of the assessee is allowed

ITA 3673/CHNY/2025[2020-21]Status: DisposedITAT Chennai17 Feb 2026AY 2020-21

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.3673/Chny/2025 िनधा&रण वष& /Assessment Year: 2020-21

For Appellant: Mr. N. Arjun Raj, AdvocateFor Respondent: Dr. M.D. Vijay Kumar, JCIT

Section 11Section 119Section 13(9)Section 139(1)Section 143(1)Section 250

suffice to reproduce para 2 of the impugned order whereby action of Income Tax Appellate Tribunal was held to be justified in allowing additional depreciation as claimed by the respondent-assessee herein: - "Additional depreciation is denied to the assessee on the ground that the assessee has failed to furnish form ... Admittedly, Form 3AA was submitted during the course of assessment proceedings and it is not in dispute that the assessee is entitled to the additional depreciation. In these circumstances, in the light of the judgment of this Court in the case of Commissioner of Income Tax v. Shivanand Electronics

BANDEKAR BROTHERS PRIVATE LIMITED,VASCO-DA-GAMA, GOA vs. ASSISTANT COMMISSIONER OF INCOME TAX, PANAJI, GOA

The appeal of the assessee is PARTLY ALLOWED in aforestated terms

ITA 38/PAN/2025[2013-14]Status: DisposedITAT Panaji11 Feb 2026AY 2013-14

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliassessment Years: 2013-14 Bandekar Brothers Pvt. Ltd. Post Box No. 11, Suvarna Bandekar Bldg., Swatantra Path, Vasco-Da-Gama Goa-403802 Pan: Aaacb5502B . . . . . . . Appellant V/S Asstt. Commissioner Of Income Tax, Circle-2(1), Panaji, Goa. . . . . . . . Respondent Represented Assessee By: Mr Pramod & Mr Shriniwas Deshpande [‘Ld. Ar’] Revenue By: Mr M Satish & Mr Renga Rajan [‘Ld. Dr’] Date Of Conclusive Hearing : 12/01/2026 Date Of Pronouncement : 11/02/2026 Order Per G. D. Padmahshali; This Assessee’S Appeal Filed U/S 253(1) Of The Income-

For Appellant: Mr Pramod & Mr Shriniwas Deshpande [‘Ld. AR’]For Respondent: Mr M Satish & Mr Renga Rajan [‘Ld. DR’]

Section 143(1)Section 143(2)Section 143(3)Section 14ASection 2(14)Section 246ASection 250Section 253(1)Section 37(1)

partially vacating disallowance made u/s 14A of the Act, (b) reversing later two consecutive disallowances made towards construction of roads/temples and disallowance of additional depreciation etc. The Ld. NFAC however, after recording his independent & concurrent findings in line with the findings rendered by the Ld. AO and placing reliance

BUILT UP,PUNE vs. ADIT, BANGLORE

In the result, the appeal of the assessee stands allowed

ITA 2531/PUN/2025[2019-2020]Status: DisposedITAT Pune10 Feb 2026AY 2019-2020

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2019-20 Built Up Adit, Cpc, Bangalore 1, Samda Apartment, Vs. Dr Ketkar Margs, Ghodke Chowk, Pune – 411004 Pan: Aaefb6432D (Appellant) (Respondent)

For Appellant: Shri V L JainFor Respondent: Shri Chandra Vijay, CIT

Section 139(1)Section 143(1)Section 80I

learned counsel appearing on behalf of the assessee is concerned, section 108(8) is an exemption provision which cannot be compared with claiming an additional depreciation under section 32(1)(ii-a) of the Act. As per the settled position of law, an assessee claiming exemption has to strictly

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 2 1 1 AHMEDABAD, AHMEDABAD vs. GUJARAT MINERAL DEVELOPMENT CO RPORATION LIMITED, AHMEDABAD

In the result, the appeal filed by the Revenue is hereby dismissed

ITA 2523/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad05 Feb 2026AY 2017-18

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 115JSection 143(3)Section 14ASection 37Section 37(1)

assessee amounting to Rs.62,91,01,252/- while computing the total income under the normal provisions of the Act. 4.2. The assessee also claimed additional depreciation of Rs.45,21,271/- and requested to revise the Written Down Value of the block of assets pertaining to Civil work of Windmill. This ... judicial precedents applicable at the time?" 2." Whether the Ld. CIT(A) has erred in law and on facts in allowing the additional depreciation on re-adjusted WDV (Civil Work of Wind Mill) of Rs. 45,21,271/- without appreciating the fact that depreciation on the Civil Work

ACITLTU-2, CHENNAI vs. ASHOK LEYLAND LIMITED, CHENNAI

In the result, the appeal filed by the Revenue is partly allowed and the appeal filed by the assessee is partly allowed for statistical purposes

ITA 945/CHNY/2018[2009-10]Status: DisposedITAT Chennai05 Feb 2026AY 2009-10

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.895/Chny/2018 िनधा"रण वष"/Assessment Year: 2009-10 Ashok Leyland Limited, Vs. The Deputy Commissioner Of 1, Sardar Patel Road, Guindy, Income Tax, Chennai 600 032. Company Circle – Ltu, Chennai. [Pan: Aaaca4651L] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.945/Chny/2018 िनधा"रण वष"/Assessment Year: 2009-10 The Assistant Commissioner Of Vs. Ashok Leyland Limited, Income Tax, 1, Sardar Patel Road, Guindy, Large Taxpayer Unit – 2, Chennai. Chennai 600 032. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Assessee By : Shri Vikram Vijayaraghavan, Advocate (Virtual) ""थ" की ओर से/Respondent By : Shri Ar V Sreenivasan, Cit सुनवाई की तारीख/ Date Of Hearing : 10.11.2025 घोषणा की तारीख /Date Of Pronouncement : 05.02.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Cross Appeals Filed By The Assessee & The Revenue Are Directed Against The Order Dated 28.12.2017 Passed By The Ld.

For Appellant: Shri Vikram Vijayaraghavan, AdvocateFor Respondent: Shri AR V Sreenivasan, CIT

raised by the assessee in challenging the action of the ld. CIT(A) in confirming the addition made on account of additional depreciation on assets. 22. We note that the Assessing Officer discussed the said issue in para 9 of the assessment order, wherein, it is noted that the assessee ... claimed additional depreciation on assets, which are grouped in block of asset eligible for depreciation @ 100%. The Assessing Officer rejected the same and added the claim of additional depreciation on assets to the income of the assessee. The ld. CIT(A), by placing reliance on the order of the Tribunal

ASHOK LEYLAND LIMITED,CHENNAI vs. DCIT COMPANY CIRCLE 1 (1), CHENNAI

In the result, the appeal filed by the Revenue is partly allowed and the appeal filed by the assessee is partly allowed for statistical purposes

ITA 895/CHNY/2018[2009-10]Status: DisposedITAT Chennai05 Feb 2026AY 2009-10

For Appellant: Shri Vikram Vijayaraghavan, AdvocateFor Respondent: Shri AR V Sreenivasan, CIT

DCIT,CC-7(2),MUMBAI, MUMBAI vs. TIME TECHNOPLAST LTD, MUMBAI

In the result, appeal of the Revenue is dismissed

ITA 6858/MUM/2025[2018-19]Status: DisposedITAT Mumbai02 Feb 2026AY 2018-19

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankarita No.6858/Mum/2025 (A.Y. 2018-19) Deputy Commissioner Of V/S. Time Technoplast Ltd., Income Tax, Central Circle – बनाम 2Nd Floor, 55, Corporate 7(2) Avenue, Saki Vihar Road, Room No. 637, Aaykar Andheri East, Mumbai – Bhavan, M.K. Road, Mumbai 400072, Maharashtra – 400020, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaact3858L Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Rakesh Joshi,ARFor Respondent: Shri Ritesh Misra, (CIT DR)

Section 115JSection 133ASection 143(3)Section 69CSection 801CSection 80I

6858/Mum/2025 A.Y. 2016-17 & 2018-19 Time Technoplast Ltd., Mumbai machinery filed by the assessee along with details of addition, deletion, depreciation, additional depreciation and net WDV year wise and also the findings of the order of Ld. CIT(A) that no corroborative evidences were brought on records ... Knitting Industries Pvt. Ltd., reported as 376 ITR 456 (SC)., wherein it is held that; “Section 32 of the Income-tax Act, 1961 - Depreciation - Additional depreciation - Assessment year 2005-06 - Even if form 3AA was not filed along with return of income but same was filed during assessment proceedings before

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