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“written down value”

DepreciationSection 43(6)Section 43(6)812 judgments

The decision most relied on for written down value is CIT v. P.J. Chemicals Ltd. (210 ITR 830), cited in 158 judgments on BharatTax.

Leading authorities on written down value

CIT v. P.J. Chemicals Ltd.
210 ITR 830 · 1994 · Supreme Court
158
citing judgments

This Supreme Court decision clarifies the conditions under which a capital subsidy received by an assessee should be reduced from the 'actual cost' of an asset for computing depreciation under Section 43(1) of the Income-tax Act, depending on whether the subsidy directly meets the cost of the asset.

Amway India Enterprises v. DCIT
111 ITD 112 · 2008 · ITAT
127
citing judgments

Depreciation is allowable on computer software, including software licenses, at the rate of 60%.

Capital Bus Service Pvt. Ltd. v. CIT
123 ITR 404 · 1980 · High Court
91
citing judgments

Depreciation under section 32 is allowable even if an asset is not actively used, provided it is kept in a condition of readiness or is put ready for use, as this amounts to passive user.

ACIT v. Progressive Constructions Ltd.
92 Taxmann.com 104 · 2018 · ITAT
63
citing judgments

Rights acquired under a concession agreement for highway construction, which generate revenue through toll collections, constitute an 'intangible asset' under section 32(1)(ii) of the Income-tax Act, 1961, eligible for depreciation, typically at 25%. This includes claiming depreciation on the opening Written Down Value (WDV) for such highway projects.

Paramjit Singh v. ITO
323 ITR 588 · 2010 · High Court
59
citing judgments

A registered sale deed, including the sale consideration disclosed therein, cannot be disregarded or contradicted by oral evidence, as documents containing all terms and conditions preclude such oral testimony.

Kirloskar Investments & Finance Ltd. v. Assistant Commissioner of Income-tax
67 ITD 504 · 1998 · ITAT
58
citing judgments

Merely providing a copy of a statement or letters is not sufficient opportunity; when oral evidence is relied upon to replace written evidence, the party against whom it is used must be allowed to cross-examine the person concerned to properly weigh the evidence.

CIT v. Shreyas S. Morakhia
342 ITR 285 · 2012 · High Court
48
citing judgments

For a share broker, the unrealised value of shares from clients or other trade balances written off is deductible as a bad debt under section 36(1)(vii) if the corresponding income was previously recognized. This principle applies to bad debts arising from revenue transactions, not capital loans.

South Indian Bank Ltd. v. CIT
262 ITR 579 · 2003 · High Court
48
citing judgments

For banks, bad debts written off from non-rural advances are not subject to the limitations of the provisos to sections 36(1)(vii) and 36(1)(viii), as these provisos apply only to rural advances; section 36(1)(viia) also applies exclusively to rural advances. Additionally, depreciation on investments valued at market price on the balance sheet date is eligible for deduction.

Judgments citing written down value

JCIT Cent. Cir. - 1(4), Mumbai vs. Grasim Industries Ltd, Mumbai

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

ITA 1559/MUM/2018[2010-11]Status: DisposedITAT Mumbai29 Apr 2024AY 2010-11

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2010-11 Grasim Industries Limited, The Dcit Cc-1(4), Corporate Finance Division, Room No. 902, 9Th Floor, Old Vs. A-2, Aditya Birla Centre, S.K. Cgo Building, M.K. Road, Ahire Marg, Worli, Mumbai-400020. Mumbai-400030. Pan No. Aaacg 4464 B Appellant Respondent Assessment Year: 2010-11 Jcit (Osd), Central Circle- Grasim Industries Limited, 1(4), A-Wing, 2Nd Floor, Aditya Room No. 902, Pratishtha Vs. Birla Centre, S.K. Ahire Bhavan, 9Th Floor, Old Cgo Marg, Worli, Building Annexe, Mumbai-400030. Mumbai-400020. Pan No. Aaacg 4464 B Appellant Respondent Assessee By : Mr. Yogesh Thar & Mr. Chaitanya Joshi Revenue By : Dr. Kishor Dhule, Cit-Dr Date Of Hearing : 03/04/2024 : Date Of Pronouncement 29/04/2024

For Appellant: Mr. Yogesh Thar &For Respondent: Dr. Kishor Dhule, CIT-DR
Section 132(1)Section 143(3)Section 153C

adopting learned CIT (A) erred in upholding the action of the AO in adopting lower opening written lower opening written down value of the block of assets for allowing down value of the block of assets for allowing depreciation allowance and ought to have directed the AO to re depreciation ... compute depreciation allowance allowable to the Appellant for the compute depreciation allowance allowable to the Appellant for the year adopting correct opening written down value consequent to year adopting correct opening written down value consequent to year adopting correct opening written down value consequent to withdrawal of dep withdrawal