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“block of assets”

DepreciationSection 2(11)Section 2(11)848 judgments

The decision most relied on for block of assets is CIT v. Meghalaya Steels Ltd. (383 ITR 217), cited in 203 judgments on BharatTax.

Leading authorities on block of assets

CIT v. Meghalaya Steels Ltd.
383 ITR 217 · 2016 · Supreme Court
203
citing judgments

Subsidies and excise duty refunds that are accounted for in the Profit and Loss account are revenue in nature, form part of business income, and are eligible for deductions under Section 80IB/80IC. Such receipts cannot be reduced from the block of assets for depreciation calculation.

CIT v. Oswal Agro Mills Ltd.
341 ITR 467 · 2012 · High Court
108
citing judgments

The Legislature abolished terminal depreciation under section 32(1)(iii) and the taxing of balancing charge under section 41(2), replacing these provisions with the requirement to reduce sale proceeds of depreciable assets from the block of assets.

CIT, Panji v. Dempo Company Limited
74 Taxmann.com 15 · 2016 · Supreme Court
62
citing judgments

The 20% tax rate under Section 112 applies to capital gains arising from the transfer of a depreciable asset, even if it is deemed a short-term capital gain under Section 50, provided the asset was held for more than 36 months. The fiction created by Section 50 for treating such gains as short-term does not alter the long-term nature of the asset for applying the tax rate under Section 112.

CIT v. Raj Pal Bhatia
333 ITR 315 · 2011 · High Court
54
citing judgments

A statement recorded under Section 132(4) during a search operation is not considered "books of account," "documents," or "assets found or seized" for the purpose of initiating search assessments under Chapter XIVB (e.g., Section 158BD or 153C). Such a statement is created during the search and cannot solely form the basis for assessment without other incriminating material found.

Sharp Business System v. CIT
254 CTR 233 · 2012 · High Court
50
citing judgments

Depreciation is allowable on a non-compete fee as it constitutes an intangible asset, even if the right acquired cannot be transferred, provided it is treated as part of a block of assets.

341 ITR 467 (Del) (3) ACIT v. S.K. Patel Family Trust
38 SOT 208 · 2010 · ITAT
34
citing judgments

Depreciation on a building used for business purposes should be allowed following the rule of consistency if it was allowed in earlier assessment orders and the Assessing Officer raised no doubts about its use.

(1) CIT v. Bharat Aluminium Co. Ltd.
187 Taxmann 111 · 2010 · High Court
25
citing judgments

Depreciation must be allowed on the entire block of assets as defined in Section 2(11) of the Income-tax Act, and individual assets of each unit cannot be considered separately for this purpose.

60 Taxman 412 (SC) II. DIT v. HSBC Asset Management (I)(P) Ltd.
47 Taxmann.com 286 · 2014 · High Court
23
citing judgments

Depreciation on an asset forming part of a block of assets must be allowed in subsequent years if it was allowed in an earlier year. The opening written down value in a year cannot be disputed if it was correctly carried forward.

Judgments citing block of assets

Franklin Templeton International Services (I) P. Ltd, Mumbai vs. Asst CIT 3(1)(OSD), Mumbai

In the result the appeal filed by the assessee for assessment year 2007-08 and 2008-09 stands partly allowed

ITA 6986/MUM/2011[2007-08]Status: DisposedITAT Mumbai13 Oct 2025AY 2007-08

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

Section 133(6)Section 92D

Franklin Templeton International Services (India) Private Limited Ground II - Depreciation allowance of Rs.8,37.562 on additions made to the block of assets in earlier years' assessments The AO erred in not allowing depreciation on the written down value ("WDV") of assets being items included to block of assets of Computer ... Appellant prays that the AO be directed to grant depreciation allowance amounting to Rs. 8,37,562 on the WDV of the block of assets, as a consequence to and consistent with such assessment orders. Ground III - Levy of interest under Section 234B of Rs.69,54,567 and 234D

Bakeri Projects Private Limited, Ahmedabad vs. The Dy.CIT, Circle-1(1)(1), Ahmedabad

In the result, the appeals of the assessee on this ground are allowed

ITA 785/AHD/2023[2016-17]Status: DisposedITAT Ahmedabad10 Oct 2025AY 2016-17

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2016-17

For Appellant: Shri S.N. Soparkar, A.RFor Respondent: Shri R.P. Rastogi, CIT-D.R
Section 143(2)Section 271(1)(c)Section 274Section 32Section 32(1)Section 32(1)(ii)Section 43(1)Section 43(6)

absence of goodwill forming part of assets in the books of the amalgamating company or in absence of goodwill forming part of block of assets as per tax records of the amalgamating company, Explanation (7) to section 43(1) and Explanation (2) to section ... absence of goodwill forming part of the assets in the books of the amalgamating company or in absence of goodwill forming part of block of assets as per tax records of the amalgamating company Explanation (7) to Section 43(1) and Explanation (2) to Section 43(6) are not applicable

Jayaram Reddy Boopesh Reddy, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-2(4), Bengaluru

In the result the appeal of the assessee is hereby partly allowed for statistical purposes

ITA 711/BANG/2025[2021-22]Status: DisposedITAT Bangalore09 Oct 2025AY 2021-22

Bench: Shri Narender Kumar Chodhry & Shri Waseem Ahmed

For Appellant: Shri Bharat, CAFor Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 132Section 132(4)Section 153A

therefore the expenses and depreciation claimed ought to be allowed. 8.10 The assessee also argued that once cars were included in the block of assets, depreciation could not be denied on an individual car. The test of user, he submitted, should be applied to the block as a whole ... purposes, full depreciation cannot be allowed under section 38(2) of the Act. 9.7 The learned CIT(A) also rejected the argument regarding block of assets, holding that user test under section 32 of the Act requires actual use for business. An asset not used for business cannot qualify merely

Jayarama Reddy Boopesh Reddy, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-2(4), Bengaluru

ITA 710/BANG/2025[2020-21]Status: DisposedITAT Bangalore09 Oct 2025AY 2020-21

Bench: Shri Narender Kumar Chodhry & Shri Waseem Ahmed

For Appellant: Shri Bharat, CAFor Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 132Section 132(4)Section 153A

therefore the expenses and depreciation claimed ought to be allowed. 8.10 The assessee also argued that once cars were included in the block of assets, depreciation could not be denied on an individual car. The test of user, he submitted, should be applied to the block as a whole ... purposes, full depreciation cannot be allowed under Section 38(2) of the Act. 9.7 The learned CIT(A) also rejected the argument regarding block of assets, holding that user test under Section 32 of the Act requires actual use for business. An asset not used for business cannot qualify merely

Jayarama Reddy Boopesh Reddy, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-2(4), Bengaluru

ITA 709/BANG/2025[2018-19]Status: DisposedITAT Bangalore09 Oct 2025AY 2018-19

Bench: Shri Narender Kumar Chodhry & Shri Waseem Ahmed

For Appellant: Shri Bharat, CAFor Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 132Section 132(4)Section 153A

therefore the expenses and depreciation claimed ought to be allowed. 8.10 The assessee also argued that once cars were included in the block of assets, depreciation could not be denied on an individual car. The test of user, he submitted, should be applied to the block as a whole ... purposes, full depreciation cannot be allowed under section 38(2) of the Act. 9.7 The learned CIT(A) also rejected the argument regarding block of assets, holding that user test under section 32 of the Act requires actual use for business. An asset not used for business cannot qualify merely

Jayarama Reddy Boopesh Reddy, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-2(4), Bengaluru

ITA 708/BANG/2025[2016-17]Status: DisposedITAT Bangalore09 Oct 2025AY 2016-17

Bench: Shri Narender Kumar Chodhry & Shri Waseem Ahmed

For Appellant: Shri Bharat, CAFor Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 132Section 132(4)Section 153A

therefore the expenses and depreciation claimed ought to be allowed. 8.10 The assessee also argued that once cars were included in the block of assets, depreciation could not be denied on an individual car. The test of user, he submitted, should be applied to the block as a whole ... purposes, full depreciation cannot be allowed under section 38(2) of the Act. 9.7 The learned CIT(A) also rejected the argument regarding block of assets, holding that user test under section 32 of the Act requires actual use for business. An asset not used for business cannot qualify merely

Jayarama Reddy Boopesh Reddy, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle 2(4), Bengaluru

ITA 706/BANG/2025[2014-15]Status: DisposedITAT Bangalore09 Oct 2025AY 2014-15

Bench: Shri Narender Kumar Chodhry & Shri Waseem Ahmed

For Appellant: Shri Bharat, CAFor Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 132Section 132(4)Section 153A

therefore the expenses and depreciation claimed ought to be allowed. 8.10 The assessee also argued that once cars were included in the block of assets, depreciation could not be denied on an individual car. The test of user, he submitted, should be applied to the block as a whole ... purposes, full depreciation cannot be allowed under section 38(2) of the Act. 9.7 The learned CIT(A) also rejected the argument regarding block of assets, holding that user test under section 32 of the Act requires actual use for business. An asset not used for business cannot qualify merely

Jayarama Reddy Boopesh Reddy, Bengaluru vs. Deputy Commissioner of Income Tax Central Cirlce-2(4), Bengaluru

ITA 705/BANG/2025[2013-14]Status: DisposedITAT Bangalore09 Oct 2025AY 2013-14

Bench: Shri Narender Kumar Chodhry & Shri Waseem Ahmed

For Appellant: Shri Bharat, CAFor Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 132Section 132(4)Section 153A

therefore the expenses and depreciation claimed ought to be allowed. 8.10 The assessee also argued that once cars were included in the block of assets, depreciation could not be denied on an individual car. The test of user, he submitted, should be applied to the block as a whole ... purposes, full depreciation cannot be allowed under section 38(2) of the Act. 9.7 The learned CIT(A) also rejected the argument regarding block of assets, holding that user test under section 32 of the Act requires actual use for business. An asset not used for business cannot qualify merely

Sharmanji Yarns Private Limited, Ludhiana vs. Principal Commissioner of Income Tax-1, Ludhiana

The appeal stand allowed in terms of our above order

ITA 706/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh08 Oct 2025AY 2020-21

Bench: SHRI LALIET KUMAR (Judicial Member), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Shri Ashwani Kumar (CA) -Ld. ARFor Respondent: Smt. Tarundeep Kaur(CIT) – Ld. DR
Section 142(1)Section 143(3)Section 263

file details of various business expenditure along with documentary evidences. The assessee was also required to explain the additions made to various block of assets viz. building, plant and machinery. 8. From assessee’s various replies as placed on record, it is quite evident that all the above notices were

Vitp Private Limited, Hyderabad vs. DCIT., Circle8(1), Hyderabad

In the result, the appeal of the assessee in ITA

ITA 574/HYD/2024[AY 2017-18]Status: DisposedITAT Hyderabad08 Oct 2025

Bench: Shri Ravish Sood (Judicial Member), Shri Madhusudan Sawdia (Accountant Member)

For Appellant: Advocates Percy Perdiwala and Mahima GoudFor Respondent: : Shri Shahnawaz-ul-Rahman
Section 115JSection 143(3)Section 263Section 43(6)Section 80I

perusal of the return of income and audit report of the assessee, he also observed that the written down value (“WDV”) of the block of assets of building and plant & machinery as on 31.03.2017 in the hands of M/s Flex Developers Pvt. Ltd. was not adopted as the actual cost ... further submitted that, as per Explanation 2 to section 43(6) of the Act, the assessee can add to its block of assets the value of assets received from subsidiary after reducing the depreciation “actually allowed” in the hands of the subsidiary. Therefore, as per the clear understanding of Explanation

Vitp Private Limited, Hyderabad vs. DCIT., Circle8(1), Hyderabad

ITA 573/HYD/2024[AY 2017-18]Status: DisposedITAT Hyderabad08 Oct 2025

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं / Ita Nos.573 & 574/Hyd/2024 (निर्धारण वर्ष/Assessment Year: 2017-18) Vitp Private Limited Vs. Dy. Cit Hyderabad Circle 8 (1) Pan:Aaccv2672G Hyderabad (Appellant) (Respondent) निर्धारिती द्वारा / Assessee By: Advocates Percy Perdiwala & Mahima Goud राजस्व द्वारा / Revenue By:: Shri Shahnawaz-Ul-Rahman, Cit(Dr) सुनवाई की तारीख / Date Of Hearing: 23/09/2025 घोषणा की तारीख / Pronouncement: 08/10/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: These Two Appeals Are Filed By Vitp Private Limited (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Principal Commissioner Of Income Tax-2, Hyderabad, (“Ld.Pcit”), Dated 30/03/2024 For The A.Y.2017-18. As Both The Appeals Are Interrelated & Belongs To The Same, Both Are Heard Together & One Consolidated Order Is Being Passed For The Sake Of Brevity.

For Appellant: Advocates Percy Perdiwala andFor Respondent: : Shri Shahnawaz-ul-Rahman
Section 143(3)Section 144BSection 144C(3)Section 263Section 80Section 801A

perusal of the ROI and audit report filed by the assessee, following observations were made : i. it was seen that WDV of block of assets of building and plant & machinery Q15% as on 31-03-2017 of M/s Flagship Developers Pvt. Ltd was not adopted as actual cost ... perusal of the return of income and audit report of the assessee, he also observed that the written down value (“WDV”) of the block of assets of building and plant & machinery as on 31.03.2017 in the hands of M/s Flex Developers Pvt. Ltd. was not adopted as the actual cost

Asst. Commissioner of Income Tax -7(1)(1), Mumbai vs. Horizon Packs Pvt. Ltd., Mumbai

In the result, appeals by the revenue are dismissed

ITA 6096/MUM/2024[2020-21]Status: DisposedITAT Mumbai06 Oct 2025AY 2020-21

Bench: Shri Saktijit Dey, Hon'Ble & Shri Narendra Kumar Billaiya, Hon'Ble

For Appellant: Shri Nitesh Joshi, A/RFor Respondent: Shri Ritesh Mishra, CIT D/R
Section 143(2)Section 32Section 801A

raised in the assessment year 2003-2004. The Assessee claimed that it is allowable as per the provisions of Income Tax Act on block of assets under the head "intangible assets". The Assessing Officer allowed the claim for that assessment year by an order under Section 143(3) dated ... Tribunal then, proceeds to hold that when the Assessing Officer had to allow depreciation on the written down value of the block of assets, then, it cannot in the present assessment year dispute the opening written down value of the block of assets nor can he examine the correctness

Assistant Commissioner of Income Tax -7(1)(1), Mumbai vs. Horizon Packs Pvt. Ltd., Mumbai

In the result, appeals by the revenue are dismissed

ITA 5950/MUM/2024[2018]Status: DisposedITAT Mumbai06 Oct 2025

Bench: Shri Saktijit Dey, Hon'Ble & Shri Narendra Kumar Billaiya, Hon'Ble

For Appellant: Shri Nitesh Joshi, A/RFor Respondent: Shri Ritesh Mishra, CIT D/R
Section 143(2)Section 32

raised in the assessment year 2003-2004. The Assessee claimed that it is allowable as per the provisions of Income Tax Act on block of assets under the head "intangible assets". The Assessing Officer allowed the claim for that assessment year by an order under Section 143(3) dated ... Tribunal then, proceeds to hold that when the Assessing Officer had to allow depreciation on the written down value of the block of assets, then, it cannot in the present assessment year dispute the opening written down value of the block of assets nor can he examine the correctness

Tourism Corporation of Gujarat Limited, Gandhinagar vs. PCIT Ahmedabad - 3, Ahmedabad

Accordingly, the appeal filed by the assessee is dismissed

ITA 1275/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad01 Oct 2025AY 2020-21

Bench: DR. BRR Kumar (Vice President), Shri Siddhartha Nautiyal (Judicial Member)

Section 143(3)Section 144BSection 263Section 43(1)

period which were credited to a deferred Government account instead of being reduced from the cost or written down value of the relevant block of assets; only a small portion of the grants was amortised to profit and loss and offered as income while depreciation was claimed on the full ... amount of that same grant already amortised and offered as income; alternatively, the AO should reduce the actual cost/WDV of the block of assets by the grant as provided in Explanation 10 to section 43(1) and ICDS-VII and then compute depreciation accordingly. Because the AO had neither added

Lupin Limited, Mumbai vs. Principal Commissioner of Income Tax - 3, Mumbai

In the result, the appeal of the assessee is allowed

ITA 3257/MUM/2025[2019-20]Status: DisposedITAT Mumbai30 Sept 2025AY 2019-20

Bench: Shri Vikram Singh Yadav & Shri Raj Kumar Chauhanassessment Year : 2019-20 Lupin Limited, Principal Commissioner Of 3Rd Floor, Kalpataru Inspire, Income Tax-3, Off Western Express Highway, Vs. Room No. 612, 6Th Floor, Santacruz (East), Aayakar Bhavan, Mumbai-400055. Maharshi Karve Road, Pan : Aaacl1069K Mumbai-400020. (Appellant) (Respondent) Assessee By : Shri Rajan Vora & Shri Pranay Gandhi Revenue By : Shri Rajesh Kumar Yadav, Cit-Dr

For Appellant: Shri Rajan Vora &For Respondent: Shri Rajesh Kumar Yadav, CIT-DR
Section 115JSection 143(3)Section 263Section 43(6)

taxable income under the head Income from Business and Profession without appreciating the fact that same has already been reduced from the block of assets as per provisions of Section 43(6) of the Act for calculation of depreciation under Income Tax Act. 8. erred in misinterpreting the definition ... computation of depreciation u/s. 32 of the Act, the assessee has reduced the insurance claim amount of Rs. 12,57,920/- in the Block of Assets. It was accordingly submitted that the order so passed by the AO was not erroneous and prejudicial to the interest of the Revenue

Pmv Maltings Pvt Ltd, New Delhi vs. ACIT Circle-19(2), New Delhi

In the result the appeal of the assessee for ITA No

ITA 6906/DEL/2019[2016-17]Status: DisposedITAT Delhi26 Sept 2025AY 2016-17

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

Section 143(3)Section 32

power, such percentage on the actual cost thereof to the assessee as may be prescribed 11;] 12[in the case of any block of assets, such percentage on the written (ii) down value thereof as may be prescribed 13:] 14[***] 15[Provided16[***] that no deduction shall be allowed under this ... hereinbelow Explanation 3 to Section 32(1) of the Act: "Explanation 3.-- For the purposes of this sub-section, the expressions 'assets' and 'block of assets' shallmean-- [a] tangible assets, being buildings, machinery, plant or furniture; Page 8 of 19 ITA Nos. 3103 & 6906/Del/2019 [b] intangible assets, being know

Pmv Maltings Pvt Ltd, New Delhi vs. ACIT Circle-19(2), New Delhi

In the result the appeal of the assessee for ITA No

ITA 3103/DEL/2019[2015-16]Status: DisposedITAT Delhi26 Sept 2025AY 2015-16

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

Section 143(3)Section 32

power, such percentage on the actual cost thereof to the assessee as may be prescribed 11;] 12[in the case of any block of assets, such percentage on the written (ii) down value thereof as may be prescribed 13:] 14[***] 15[Provided16[***] that no deduction shall be allowed under this ... hereinbelow Explanation 3 to Section 32(1) of the Act: "Explanation 3.-- For the purposes of this sub-section, the expressions 'assets' and 'block of assets' shallmean-- [a] tangible assets, being buildings, machinery, plant or furniture; Page 8 of 19 ITA Nos. 3103 & 6906/Del/2019 [b] intangible assets, being know

Tata Communications Limited, Mumbai vs. Principle Commissioner of Income Tax, Mumbai

In the result, the question of law referred to the Special Bench is answered in favour of the assessee

ITA 3515/MUM/2025[2018-19]Status: DisposedITAT Mumbai25 Sept 2025AY 2018-19

Bench: Shri Saktijit Dey & Shri Arun Khodpiatata Communications Limited Pr. Cit, Videsh Sanchar Bhavan, Mumbai-1 Vs. M. G. Road, Fort, Mumbai-400 001 Pan/Gir No. Aaacv 2808 C (Appellant) : (Respondent) Appellant By : Shri J. D. Mistri Respondent By : Shri Ritesh Misra, Cit Dr Date Of Hearing : 25.09.2025 Date Of Pronouncement : 25.09.2025 O R D E R Per Saktijit Dey: The Present Appeal, At The Instance Of The Assessee, Assails Order Dated 21.03.2025, Passed U/S. 263 Of The Income Tax Act, 1961 (‘The Act’ For Short), By Learned Principal Commissioner Of Income Tax (‘Ld. Pcit’ For Short), Pertaining To The Assessment Year (A.Y.) 2018-19. 2. Though The Assessee Has Raised Multiple Grounds, Both On Jurisdictional Issues As Well As On Merits, However, There Is Consensus Between The Parties That The Appeal Can Be Decided On Merits, In Which Event, There Is No Need To Go Into Various Other Issues Raised In Appeal.

For Appellant: Shri J. D. MistriFor Respondent: Shri Ritesh Misra, CIT DR
Section 112Section 143(3)Section 263Section 50

under:- 50. Notwithstanding anything contained in clause (42A) of section 2, where the capital asset is an asset forming part of a block of assets in respect of which depreciation has been allowed under this Act or under the Indian Income- tax Act, 1922 (11 of 1922), the provisions ... full value of such consideration received or accruing as a result of the transfer of any other capital asset falling within the block of assets during the previous year, exceeds the aggregate of the following amounts, namely:- (i) expenditure incurred wholly and exclusively in connection with such transfer or transfers

Blue Ocean Resorts Private Limited, Delhi vs. ITO Ward 5(1), Delhi

Appeal is allowed

ITA 4946/DEL/2025[2018-19]Status: DisposedITAT Delhi23 Sept 2025AY 2018-19

Bench: Sh. Satbeer Singh Godaraita No. 4946/Del/2025 : Asstt. Year : 2018-19 Blue Ocean Resorts Pvt. Ltd., Vs Income Tax Officer, 52A, Friends Colony East, Ward-5(1), New Delhi-110065 New Delhi-110002 (Appellant) (Respondent) Pan No. Aadcb5036D Assessee By: Ms. Lalitha Krishnamurthy, Ca & Ms. Bhawna Khatri, Ca Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 23.09.2025 Date Of Pronouncement: 23.09.2025 Order This Assessee’S Appeal For Assessment Year 2018-19, Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2024-25/1064596082(1) Dated 02.05.2024, In Proceedings U/S 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Ms. Lalitha Krishnamurthy, CA &For Respondent: Sh. Manoj Kumar, Sr. DR
Section 143(3)

Revenue side. It is therefore concluded that once the above fixed asset has been allowed to form part of the assessee’s corresponding block of assets, it is no more open for the learned lower authorities to decline either the corresponding depreciation or all other relevant expenditure; and, therefore

DCIT, Circle-7(1), Delhi vs. Fmi Automotive Components Private Limited, Haryana

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

ITA 3489/DEL/2024[2017-18]Status: DisposedITAT Delhi22 Sept 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shris.Rifaur Rahmandcit, Circle 7 (1), Vs. Fmi Automotive Components Private Limited, Delhi. Plot No.1, Subplot 4, 5, 8 & 9 Msil, Supplier Park, Phase 3A, Imt Manesar, Gurgaon – 1222 050 (Haryana). (Pan :Aabcf1682P) (Appellant) (Respondent) Assessee By :Shri S.K. Agarwal, Ca Revenue By :Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing : 24.06.2025 Date Of Order : 22.09.2025 O R D E R Per S. Rifaur Rahman: 1. The Revenue Has Filed Appeal Against The Order Of The Learned Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi [“Ld. Cit(A)”, For Short] Dated 30.05.2024 For The Assessment Year 2017-18 Raising Following Grounds Of Appeal :- “1. Whether On The Facts & Circumstances Of The Case & In Law, The Ld Nfac Has Erred In Allowing The Appeal Of The Assessee By Deleting The Addition Made By The Ao Amounting To Rs.5,90,59,019/- On Account Of Disallowance Of Foreign Exchange Loss On Account Of Plant & Machinery.

For Appellant: Shri S.K. Agarwal, CAFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 143(1)Section 143(2)Section 41

reflected in P&L account. 3.1 It is seen from detailed submissions of the appellant that the amount has been added in the block of assets under section 43A and reflected in audit report as shown below :- ………….. However, the Assessing Officer contending that the amount has not been added ... assessee as a onetime occurrence. The appellant submitted details of insurance claim towards damage to servo motor which was part of block of assets as Plant and Machinery. As per section 45(1 A) any profit arising on receipt of claim from Insurance company on account of damage or destruction