“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

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

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

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

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

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

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

DCIT., Circle-13(1), Hyderabad vs. The Singareni Collieries Company Limited, Kothagudem

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

ITA 307/HYD/2024[2018-19]Status: DisposedITAT Hyderabad10 Sept 2025AY 2018-19

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.285/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2018-19) M/S. Singareni Collieries Co. Ltd., Dy. Commissioner Of Income Tax, Vs. Circle 13(1), Hyderabad. Kothagudem. Pan:Aaact8873F (Appellant) (Respondent) आ.अपी.सं /Ita No.307/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2018-19) Dy. Commissioner Of Income Tax, M/S. Singareni Collieries Co. Ltd., Circle 13(1), Hyderabad. Vs. Kothagudem. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri M.V. Anil Kumar, Advocate & Shri C.H.Venkatesh, C.A. रधजस् व द्वधरध/Revenue By: Ms.U. Mini Chandran, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 25/08/2025 घोर्णध की तधरीख/Pronouncement: 10/09/2025

For Appellant: Shri M.V. Anil Kumar, Advocate and Shri C.H.Venkatesh, C.AFor Respondent: Ms.U. Mini Chandran, CIT-DR

Section 143(2)Section 143(3)Section 144B

observations, we allow this ground of appeal of the assessee by holding that the assessee is entitled to charge depreciation @ 15% under the block of assets "plant and machinery", as against 10% made by the AO.” 7.3.2 All the facts of the case, Grounds of appeal, statement of facts, online

Singareni Collieries Company Limited, Kothagudem vs. DCIT., Circle-13(1), Hyderabad

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

ITA 285/HYD/2024[2018-19]Status: DisposedITAT Hyderabad10 Sept 2025AY 2018-19

For Appellant: Shri M.V. Anil Kumar, Advocate and Shri C.H.Venkatesh, C.AFor Respondent: Ms.U. Mini Chandran, CIT-DR

Section 143(2)Section 143(3)Section 144B

Perfect Filaments Limited, Mumbai vs. Principal Commissioner of Income Tax Circle -4, Mumbai

In the result, the appeal by the assessee is partly allowed in terms of our aforesaid decision

ITA 3501/MUM/2025[2020-21]Status: DisposedITAT Mumbai10 Sept 2025AY 2020-21

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhailperfect Filaments Limited, E-23/24/25/26, Commerce Centre, Tardeo Road Tulsi Wadi, S.O., ............... Appellant Mumbai - 400034 Pan : Aaacp4215F V/S Principal Commissiioner Of Income Tax-4 ……………… Respondent 6Th Floor, Aayakar Bhavan, M.K. Road, Mumbai – 400020 Assessee By : Shri Dharan Gandhi Revenue By : Shri R.A. Dhyani, Cit-Dr

For Appellant: Shri Dharan GandhiFor Respondent: Shri R.A. Dhyani, CIT-DR

Section 143(3)Section 201Section 263Section 40Section 80G

factually incorrect since the assessee has shown capital gain on sale of land and on building the sale consideration has reduced from block of assets. Further, the Ld. AO in the assessment proceedings has duly verified by making specific enquires on the above aspects. ITA No.3501/Mum./2025

Sprit Infrapower & Multiventures Private Limited, Mumbai vs. PCIT-8, Mumbai

The appeal of the assessee is allowed

ITA 1589/MUM/2025[2018-19]Status: DisposedITAT Mumbai10 Sept 2025AY 2018-19

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

For Appellant: Shri Madhur Agrawal, AR

Section 143(3)Section 263Section 32(1)

goodwill is fully impaired in AY 2014-15. Section 32(1) states that the one condition for claiming depreciation is that the block of assets should "exist" to claim depreciation. Since, goodwill is not treated as an asset in its books of accounts, the question of allowing depreciation on such ... question of allowability of depreciation has to be examined, in the light of provision of section 32(1), where it mandates the block of assets should exists to claim depreciation. Since, goodwill is not treated as an asset in its books of accounts and also, the assessee is not getting

Agri Gold Foods and Farm Products Limited, Vijayawada vs. Asst.Commissioner of Income Tax, Circle-2(1), Vijayawada

ITA 2000/HYD/2017[2007-08]Status: DisposedITAT Visakhapatnam09 Sept 2025AY 2007-08

Bench: Us:

Section 143(3)

view, not applicable to appellant's case. 5.3.12. The appellant had not transferred the deferred revenue expenditure to the land value (i e) block of assets (i.e.) block of asset under the head "land" was not capitalised. Without capitalization, the allowability of expenditure at the time of transfer is questionable ... Appellant should have adopted cost of the land for transfer to subsidiary company at Rs.1.59.53,391 it- as per the value in block of assets (land) in the Balance Sheet of the appellant as on 31.03.2007. Appellant included the deferred revenue expenditure of Rs 8,76,42,368/- with

ACIT Central Circle 7 4, Mumbai vs. Zytex Biotech Private Limited, Mumbai

The appeal of the revenue is dismissed

ITA 492/MUM/2025[2014-15]Status: DisposedITAT Mumbai09 Sept 2025AY 2014-15

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Appellant: Shri, Swapnil Choudhary, Sr. DR

Section 133ASection 143(3)Section 147Section 148Section 2Section 250Section 50(2)Section 50B

Consequently, the transaction should have been classified under Section 50(2) as Short-Term Capital Gains (STCG) arising from the cessation of a "block of assets." 4. "Whether on the facts and circumstances of the case and in law, the Learned CIT(A) is justified in law and on facts

DCIT Cen Cir 1(4), Mumbai vs. Grasim Industries Ltd, Mumbai

In the result, appeal of the revenue and the assessee are partly allowed, and the additional ground of the assessee is dismissed

ITA 4069/MUM/2016[2010-11]Status: DisposedITAT Mumbai09 Sept 2025AY 2010-11

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjee

For Appellant: Shri J.D. Mistry – Sr. Advocate &For Respondent: Shri Arun Kanti Datta - CIT DR

Section 143(3)Section 250Section 260ASection 43BSection 45Section 801ASection 801A(4)

assessee is succeeded. Ground No. 2 raised by the assessee is allowed. In relation to Ground No.3 – Depreciation on assets added to the block of assets and subsequently let out: 51. The assessee let out its office premises in Sakhar Bhavan and Dalamal Towers at Nariman Point, Mumbai, and Ahura ... computation of income, the assessee claimed depreciation on these let out properties by stating that once the asset is added to the block of asset, it loses its identity and depreciation on such a particular asset cannot be worked out separately. The Ld. AO noted in order that the assessee

Grasim Industries Limited, Mumbai vs. DCIT, CC-1(4), Mumbai

In the result, appeal of the revenue and the assessee are partly allowed,

ITA 2897/MUM/2016[2010-11]Status: DisposedITAT Mumbai09 Sept 2025AY 2010-11

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjee

For Appellant: Shri J.D. Mistry – Sr. Advocate &For Respondent: Shri Arun Kanti Datta - CIT DR

Section 143(3)Section 250Section 260ASection 43BSection 45Section 801ASection 801A(4)

Maxxis Rubber India Pvt. Ltd., Ahmedabad vs. The Pr. CIT, Ahmedabad-1, Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1129/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad08 Sept 2025AY 2018-19

Bench: Smt. Annapurna Gupta & Shri T.R. Senthil Kumar

For Appellant: Respondent byFor Respondent: Shri Sher Singh, CIT-DR

Section 143(3)Section 263Section 32Section 32(1)

section 32(1)(ii) of the Act. A working of the total depreciation charged during the year under consideration is tabulated as under:- Block of assets Plant and Machinery S.No. 15 30 40 Rate (%) (i) (ii) (iii) 3a Written down value on the first ... previous year 3b Written down value on the first day - - 23,10,31,519 of previous year, of those block of assets which were eligible for depreciation @ 50%, 60% or 80% as per the old Table 4 Additions for a period of 180 days

Ebix Travels Pvt. Ltd., New Delhi vs. DCIT, Circle 2(2)(1), Bangalore

In the result appeal of the assessee is partly allowed

ITA 47/BANG/2025[2021-22]Status: DisposedITAT Bangalore29 Aug 2025AY 2021-22

Bench: Shri Prashant Maharishi & Shri Soundararjan K

Section 143Section 144BSection 144CSection 234ASection 234BSection 32Section 92CSection 92D

above sum by disallowing the depreciation and issued the show cause notice. Assessee replied that there is no new addition to the total block of assets of the depreciable assets and it has come only from the opening balance. The assessee has not purchased any assets, but it is only ... against not allowing the depreciation of ₹ 1845,615/– to the assessee. The assessee has produced a chart which shows that in the block of assets the assessee has one particular asset of Patents and Copyrights. These assets in assessment year 2019 – 20 had opening written down value

M/S. Ajk Investments Private Limited, Mumbai vs. Assistant Commissioner of Income Tax -1(1)(1), Mumbai

In the result, the appeal filed by the assessee is allowed for statistical purpose

ITA 4362/MUM/2025[2014-15]Status: DisposedITAT Mumbai29 Aug 2025AY 2014-15

Bench: MS. KAVITHA RAJAGOPAL (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

For Appellant: Shri Prakash JotwaniFor Respondent: Shri Pitamber Kumar, Addl. CIT

Section 115Section 143(1)Section 143(2)Section 143(3)Section 2(22)Section 2(22)(a)Section 250Section 250(6)

Assessing Officer ('ld. A.O.' for short) observed that the assessee has claimed depreciation on fixed assets amounting to Rs. 57,06,162/- from block of assets viz. ‘land at Alibaug’ but had not offered any capital gain on the said transaction. The assessee contended that the land was asset

ACIT (Ltu), Circle-2, New Delhi vs. International Tractor Ltd., Delhi

In the result, the Revenue’s Appeal No

ITA 8975/DEL/2019[2012-13]Status: DisposedITAT Delhi29 Aug 2025AY 2012-13

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay, Accoutant Member

For Appellant: Sh. Shankey Agrawal, Adv., Nikky Jhamtani, CA, ShFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR

Section 115JSection 143(1)Section 143(2)Section 143(3)Section 35Section 37Section 80J

disallowed, which was confirmed by the Ld. CIT(A). Ld. AR has submitted that there has been no addition in the block of assets in relation to energy savings devices during the year under consideration and 6 the claim of 80% depreciation on energy saving devices was not pressed before

ACIT (Ltu), Circle-2, New Delhi vs. International Tractor Ltd., Delhi

In the result, the Revenue’s Appeal No

ITA 8974/DEL/2019[2011-12]Status: DisposedITAT Delhi29 Aug 2025AY 2011-12

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay, Accoutant Member

For Appellant: Sh. Shankey Agrawal, Adv., Nikky Jhamtani, CA, ShFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR

Section 115JSection 143(1)Section 143(2)Section 143(3)Section 35Section 37Section 80J

International Tractors Ltd., Delhi vs. DCIT (Ltu), Circle-1, New Delhi

In the result, the Revenue’s Appeal No

ITA 7410/DEL/2019[2013-14]Status: DisposedITAT Delhi29 Aug 2025AY 2013-14

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay, Accoutant Member

For Appellant: Sh. Shankey Agrawal, Adv., Nikky Jhamtani, CA, ShFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR

Section 115JSection 143(1)Section 143(2)Section 143(3)Section 35Section 37Section 80J

International Tractors Ltd., Delhi vs. DCIT, New Delhi

Accordingly. Accordingly, this ground is allowed for

ITA 160/DEL/2017[2012-13]Status: DisposedITAT Delhi29 Aug 2025AY 2012-13

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay, Accoutant Member

For Appellant: Sh. Shankey Agrawal, Adv., Nikky Jhamtani, CA, ShFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR

Section 115JSection 143(1)Section 143(2)Section 143(3)Section 35Section 37Section 80J

disallowed, which was confirmed by the Ld. CIT(A). Ld. AR has submitted that there has been no addition in the block of assets in relation to energy savings devices during the year under consideration and the claim of 80% depreciation on energy saving devices was not pressed before

International Tractors Ltd., New Delhi vs. DCIT (Ltu), New Delhi

Accordingly. Accordingly, this ground is allowed for

ITA 3519/DEL/2016[2011-12]Status: DisposedITAT Delhi29 Aug 2025AY 2011-12

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay, Accoutant Member

For Appellant: Sh. Shankey Agrawal, Adv., Nikky Jhamtani, CA, ShFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR

Section 115JSection 143(1)Section 143(2)Section 143(3)Section 35Section 37Section 80J

M/S. International Tractor Ltd., Delhi vs. DCIT, New Delhi

In the result, the Revenue’s Appeal No

ITA 2619/DEL/2015[2010-11]Status: DisposedITAT Delhi29 Aug 2025AY 2010-11

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay, Accoutant Member

For Appellant: Sh. Shankey Agrawal, Adv., Nikky Jhamtani, CA, ShFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR

Section 115JSection 143(1)Section 143(2)Section 143(3)Section 35Section 37Section 80J

DCIT, New Delhi vs. M/S. International Tractor Ltd., Delhi

In the result, the Revenue’s Appeal No

ITA 2618/DEL/2015[2010-11]Status: DisposedITAT Delhi29 Aug 2025AY 2010-11

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay, Accoutant Member

For Appellant: Sh. Shankey Agrawal, Adv., Nikky Jhamtani, CA, ShFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR

Section 115JSection 143(1)Section 143(2)Section 143(3)Section 35Section 37Section 80J

Deputy Commissioner of Income Tax, Guwahati vs. Sankha Press Pvt Ltd, Guwahati

ITA 127/GTY/2025[2017-18]Status: DisposedITAT Guwahati28 Aug 2025AY 2017-18

Bench: Shri Rajesh Kumar, Am & Shri Manomohan Das, Jm

For Appellant: Shri Soumitra Choudhury, ARFor Respondent: Shri Kaushik Ray, DR

Section 69C

assets did not cease to exist as the entire sale consideration of sale of vehicle had been adjusted and reduced from the said block of asset depreciable at 15% depreciation. However, the ld. AO added the amount to the income of the assessee on the ground that the assessee ... entire sale prices of ₹3,85,000/- was adjusted in the schedule of depreciation. The ld. CIT (A) noted that since the block of assets (Motor Car) having rate of depreciation at 15% did not cease to Sankha Press Pvt. Ltd.; A.Ys. 2016-17 & 2017-18 ITA No. 126& 127/GTY/2025

Deputy Commissioner of Income Tax, Guwahati vs. Sankha Press Pvt Ltd, Guwahati

ITA 126/GTY/2025[2016-17]Status: DisposedITAT Guwahati28 Aug 2025AY 2016-17

Bench: Shri Rajesh Kumar, Am & Shri Manomohan Das, Jm

For Appellant: Shri Soumitra Choudhury, ARFor Respondent: Shri Kaushik Ray, DR

Section 69C