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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

Jaipur Telecom Private Limited, Jaipur vs. DCIT Circle 1, Jpr, Jaipur

In the result the appeal of the assessee in ITA no

ITA 788/JPR/2023[2017-18]Status: DisposedITAT Jaipur22 Apr 2024AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Tarun Mittal (C.A.)For Respondent: Smt. Monisha Choudhary (Addl. CIT)
Section 143(3)Section 270ASection 43(1)

such rented buildings. During the course of scrutiny assessment, it was stated by ld.AO that depreciation on buildings was to be charged on Written Down Value as computed in accordance with explanation to section 43(1). On the other hand, assessee on the basis of certain judicial rulings in favour ... that depreciation is admissible however, as regards quantum is concerned, the ld. AO was of view that it is to be given on written down value considering the explanation to section 43(1). This view of the ld. AO was challenged before the ld. CIT(A). The order

Diadora Shoes Pvt Ltd, Calicut vs. ACIT Circle 2(1), Calicut

In the result, the assessee’s appeal is allowed

ITA 92/COCH/2023[2014-15]Status: DisposedITAT Cochin19 Apr 2024AY 2014-15

Bench: Shri Sanjay Arora, Am & Shri Anil Kumar Dugar, Jm

For Appellant: --- None ---For Respondent: Smt.J.M.Jamuna Devi, Sr.DR
Section 250Section 32(1)(iia)

actual cost thereof to the assessee as may be prescribed; (ii) in the case of any block of assets, such percentage on the written down value thereof as may be prescribed: Provided .............. Provided further that where an asset referred to in clause (i) or clause (ii) or clause

Genpact Services Llc, Gurgaon vs. ACIT, Circle-1(3)(1), International Taxation, New Delhi

In the result, the appeal of the assessee is allowed

ITA 1833/DEL/2022[2017-18]Status: DisposedITAT Delhi19 Apr 2024AY 2017-18

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.Genpact Services Llc, Vs. Acit, Plot No. 22A & B, Circle-1(3)(1), Sector-18, Udyog Vihar, International Taxation, Gurgaon, Haryana New Delhi (Appellant) (Respondent) Pan: Aaccg3353P

For Appellant: Shri Vishal Kalra, AdvFor Respondent: Shri Rajesh Kumar, CIT DR
Section 92C

Appellant is eligible to claim depreciation allowance of Rs 73,95,017 (being depreciation at the rate of 25% on the written down value of intangible assets so created in AY 2010-11) for the AY 2017-18. However, the said depreciation of Rs.73,95,017 has not been allowed

Diadora Shoes Pvt Ltd, Calicut vs. ACIT Circle 2(1), Calicut

In the result, the assessee’sappeal is allowed

ITA 213/COCH/2023[2015-16]Status: DisposedITAT Cochin28 Mar 2024AY 2015-16

Bench: Shri Sanjay Arora & Shri Manomohan Dasdiadora Shoes Pvt. Ltd. Asst. Cit, Circle - 2 Vkc Tower, Kolathra P.O Calicut 673001 Vs. Calicut 673655 [Pan:Aabcd9692D] (Appellant) (Respondent)

For Appellant: Shri M.V. Venugopal, CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 143(3)Section 32(1)(ii)

actual cost thereof to the assessee as may be prescribed; (ii) in the case of any block of assets, such percentage on the written down value thereof as may be prescribed: Provided .............. 2 Diadora Shoes Pvt. Ltd. v. Asst. CIT, Circle - 2 Provided further that where an asset referred

M/S Coastal Energen Private Limited, Chennai vs. ACIT, Central Circle-1(1), Chennai

In the result, the appeal stand dismissed

ITA 1483/CHNY/2023[2017-18]Status: DisposedITAT Chennai22 Mar 2024AY 2017-18

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.1481/Chny/2023 (िनधा*रण वष* / Assessment Year: 2015-16) & आयकरअपील सं./ Ita No.1482/Chny/2023 (िनधा*रण वष* / Assessment Year: 2016-17) & आयकरअपील सं./ Ita No.1483/Chny/2023 (िनधा*रण वष* / Assessment Year: 2017-18) M/S. Coastal Energen Private Limited Acit बनाम No.5, Bhuhari Building, Moores Road, Central Circle-1(1), / Vs. Egmore, Chennai-600 004. Chennai. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aadcc-0886-G (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri B. Ramakrishnan (Ca)- Ld. Ar " थ"कीओरसे/Respondent By : Shri N. Balakrishnan (Cit)-Ld. Dr सुनवाईकीतारीख/Date Of Final Hearing : 14-03-2024 घोषणाकीतारीख /Date Of Pronouncement : 22-03-2024 आदेश / O R D E R Manoj Kumar Aggarwal () 1.1 Aforesaid Appeals By Assessee For Assessment Years (Ay) 2015- 16 To 2017-18 Arise Out Of The Common Order Of Learned Commissioner Of Income Tax (Appeals)-18, Chennai [Cit(A)] Dated 31-10-2023 In The Matter Of Separate Assessments Framed By Ld. Assessing Officer [Ao]

For Appellant: Shri B. Ramakrishnan (CA)- Ld. ARFor Respondent: Shri N. Balakrishnan (CIT)-Ld. DR
Section 132Section 143(3)Section 153ASection 32Section 43(6)

unrelated vendors based on the ‘lowest bidder’. The attention was also drawn to the provisions of Sec. 43(6) for the submission that Written Down Value (WDV) do not encompass any reduction in the value of the existing assets in the block except when it was sold. There ... cost thereof, if any, as has been met directly or indirectly by any other person or authority. Further, as per Sec. 43(6) written down value means, in the case or assets acquired in the previous year, the actual cost to the assessee. Accordingly, when the assets are purchased during

M/S Coastal Energen Private Limited, Chennai vs. ACIT, Central Circle-1(1), Chennai

In the result, the appeal stand dismissed

ITA 1482/CHNY/2023[2016-17]Status: DisposedITAT Chennai22 Mar 2024AY 2016-17

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.1481/Chny/2023 (िनधा*रण वष* / Assessment Year: 2015-16) & आयकरअपील सं./ Ita No.1482/Chny/2023 (िनधा*रण वष* / Assessment Year: 2016-17) & आयकरअपील सं./ Ita No.1483/Chny/2023 (िनधा*रण वष* / Assessment Year: 2017-18) M/S. Coastal Energen Private Limited Acit बनाम No.5, Bhuhari Building, Moores Road, Central Circle-1(1), / Vs. Egmore, Chennai-600 004. Chennai. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aadcc-0886-G (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri B. Ramakrishnan (Ca)- Ld. Ar " थ"कीओरसे/Respondent By : Shri N. Balakrishnan (Cit)-Ld. Dr सुनवाईकीतारीख/Date Of Final Hearing : 14-03-2024 घोषणाकीतारीख /Date Of Pronouncement : 22-03-2024 आदेश / O R D E R Manoj Kumar Aggarwal () 1.1 Aforesaid Appeals By Assessee For Assessment Years (Ay) 2015- 16 To 2017-18 Arise Out Of The Common Order Of Learned Commissioner Of Income Tax (Appeals)-18, Chennai [Cit(A)] Dated 31-10-2023 In The Matter Of Separate Assessments Framed By Ld. Assessing Officer [Ao]

For Appellant: Shri B. Ramakrishnan (CA)- Ld. ARFor Respondent: Shri N. Balakrishnan (CIT)-Ld. DR
Section 132Section 143(3)Section 153ASection 32Section 43(6)

unrelated vendors based on the ‘lowest bidder’. The attention was also drawn to the provisions of Sec. 43(6) for the submission that Written Down Value (WDV) do not encompass any reduction in the value of the existing assets in the block except when it was sold. There ... cost thereof, if any, as has been met directly or indirectly by any other person or authority. Further, as per Sec. 43(6) written down value means, in the case or assets acquired in the previous year, the actual cost to the assessee. Accordingly, when the assets are purchased during

M/S Coastal Energen Private Limited, Chennai vs. ACIT, Central Circle-1(1), Chennai

In the result, the appeal stand dismissed

ITA 1481/CHNY/2023[2015-16]Status: DisposedITAT Chennai22 Mar 2024AY 2015-16

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.1481/Chny/2023 (िनधा*रण वष* / Assessment Year: 2015-16) & आयकरअपील सं./ Ita No.1482/Chny/2023 (िनधा*रण वष* / Assessment Year: 2016-17) & आयकरअपील सं./ Ita No.1483/Chny/2023 (िनधा*रण वष* / Assessment Year: 2017-18) M/S. Coastal Energen Private Limited Acit बनाम No.5, Bhuhari Building, Moores Road, Central Circle-1(1), / Vs. Egmore, Chennai-600 004. Chennai. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aadcc-0886-G (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri B. Ramakrishnan (Ca)- Ld. Ar " थ"कीओरसे/Respondent By : Shri N. Balakrishnan (Cit)-Ld. Dr सुनवाईकीतारीख/Date Of Final Hearing : 14-03-2024 घोषणाकीतारीख /Date Of Pronouncement : 22-03-2024 आदेश / O R D E R Manoj Kumar Aggarwal () 1.1 Aforesaid Appeals By Assessee For Assessment Years (Ay) 2015- 16 To 2017-18 Arise Out Of The Common Order Of Learned Commissioner Of Income Tax (Appeals)-18, Chennai [Cit(A)] Dated 31-10-2023 In The Matter Of Separate Assessments Framed By Ld. Assessing Officer [Ao]

For Appellant: Shri B. Ramakrishnan (CA)- Ld. ARFor Respondent: Shri N. Balakrishnan (CIT)-Ld. DR
Section 132Section 143(3)Section 153ASection 32Section 43(6)

unrelated vendors based on the ‘lowest bidder’. The attention was also drawn to the provisions of Sec. 43(6) for the submission that Written Down Value (WDV) do not encompass any reduction in the value of the existing assets in the block except when it was sold. There ... cost thereof, if any, as has been met directly or indirectly by any other person or authority. Further, as per Sec. 43(6) written down value means, in the case or assets acquired in the previous year, the actual cost to the assessee. Accordingly, when the assets are purchased during

Chimera Industrial and Development Private Limited, Mumbai vs. Commissioner of Income Tax (Appeals)-NFAC, Mumbai

In the result, both the appeals of the assessee are allowed in the terms

ITA 2332/MUM/2023[2017-18]Status: DisposedITAT Mumbai19 Mar 2024AY 2017-18

Bench: Justice (Retd.) C.V. Bhadang () & Shri B.R. Baskaran (Am)

For Appellant: a) Disallowance of depreciation on goodwill
Section 143(3)Section 147Section 234B

under development. Chimera Industrial & Development Put. Ltd. 5.2 In AY 2016-17, i.e., the year under consideration, the assessee claimed depreciation on the Written Down Value (WDV) of Good will. The depreciation so claimed was Rs.37.60 crores. However, the Assessing Officer disallowed claim for depreciation on the following reasons ... present assessment year is AY 2016-17 is the second year. During second and subsequent years, the depreciation shall be allowed on the “Written Down Value” (WDV) of assets. In our view, the conditions prescribed for allowing depreciation on an asset, viz., cost of asset, its actual user

Chimera Industrial and Development Private Limited, Mumbai vs. Commissioner of Income Tax (Appeals)-NFAC, Mumbai

ITA 2331/MUM/2023[2016-2017]Status: DisposedITAT Mumbai19 Mar 2024AY 2016-2017

Bench: Justice (Retd.) C.V. Bhadang () & Shri B.R. Baskaran (Am)

For Appellant: a) Disallowance of depreciation on goodwill
Section 143(3)Section 147Section 234B

Will and other Intangible assets under development. 5.2 In AY 2016-17, i.e., the year under consideration, the assessee claimed depreciation on the Written Down Value (WDV) of Good will. The depreciation so claimed was Rs.37.60 crores. However, the Assessing Officer disallowed claim for depreciation on the following reasons

Lupin Ltd., Mumbai vs. The Dy CIT, Circle-3(4), Mumbai

In the result, the appeal of the assessee in I

ITA 77/MUM/2021[2013-14]Status: DisposedITAT Mumbai18 Mar 2024AY 2013-14

Bench: Shri Pavan Kumar Gadale, Jm & Ms Padmavathy S, Am

For Appellant: Shri Rajan Vora, Shri PranayFor Respondent: Ms. Manju Thakur, Sr. DR
Section 10ASection 115JSection 143(3)Section 154Section 271(1)(c)Section 37(1)

purchases and expenses which were capitalized in the books of accounts. The AO called on the assessee to furnish the depreciation on the written down value of the disallowed purchases for the year under consideration and accordingly disallowed the depreciation on said unverified purchases for the AY 2013-14 also ... fresh examination. We notice, that the disallowance made by the AO towards unverified purchases and expenses is the consequential depreciation on the written down value of the assets. The relevant observations of the coordinate bench are extracted below – Unverified Expenditure “6.4 In our view, we may leave aside the issue

Asstt. CIT -Circle-3(4), Mumbai vs. M/S. Lupin Ltd., Mumbai

In the result, the appeal of the assessee in I

ITA 1241/MUM/2021[2013-14]Status: DisposedITAT Mumbai18 Mar 2024AY 2013-14

Bench: Shri Pavan Kumar Gadale, Jm & Ms Padmavathy S, Am

For Appellant: Shri Rajan Vora, Shri PranayFor Respondent: Ms. Manju Thakur, Sr. DR
Section 10ASection 115JSection 143(3)Section 154Section 271(1)(c)Section 37(1)

purchases and expenses which were capitalized in the books of accounts. The AO called on the assessee to furnish the depreciation on the written down value of the disallowed purchases for the year under consideration and accordingly disallowed the depreciation on said unverified purchases for the AY 2013-14 also ... fresh examination. We notice, that the disallowance made by the AO towards unverified purchases and expenses is the consequential depreciation on the written down value of the assets. The relevant observations of the coordinate bench are extracted below – Unverified Expenditure “6.4 In our view, we may leave aside the issue

Publics Communications P.Ltd, Mumbai vs. DCIT Cir 7(3)(2), Mumbai

In the result, ground 2 is allowed and ground 3 is allowed for statistical purposes

ITA 588/MUM/2017[2012-13]Status: DisposedITAT Mumbai15 Mar 2024AY 2012-13

Bench: Ms. Kavitha Rajagopal() & Ms. Padmavathy S. ()

Section 199

AAPL] respectively). 2 : 2 Without prejudice to the above, it is submitted that the Appellant should be allowed depreciation of Rs. 82.635 on written down value of business and commercial rights of Rs. 3,30.542 in the nature of intangible assets acquired pursuant to merger with AAPL

Ronak Ceramic Ind Ltd, Mehsana vs. Income Tax Officer, Mehsana

In the result, the appeal of the assessee is allowed

ITA 589/AHD/2023[2016-2017]Status: DisposedITAT Ahmedabad08 Mar 2024AY 2016-2017

Bench: Shri Waseem Ahmed (Accountant Member), Ms. Madhumita Roy (Judicial Member)

For Appellant: Shri Sumit Shingala, A.RFor Respondent: Shri B.P. Makwana, Sr. D.R
Section 50

shown the impugned assets being land and building as part of the block of asset and claimed the depreciation thereon. Therefore, the written down value of Rs. 7,67,802/- should be allowed as a deduction against the compensation received. 4. However, the ld. CIT(A) disagreed with the submission ... such, we note that the ld. CIT(A) on the one hand is denying the benefit of a deduction representing the written down value of Rs. 7,67,802/- and on the other hand, the ld. CIT(A) has not given the benefit of acquisition of land along with

ACIT, Circle CC 15, New Delhi vs. Alka Mendiratta, Delhi

In the result, the appeals of the Revenue are dismissed and the Cross Objections of the assessees are also dismissed

ITA 1864/DEL/2021[2016-17]Status: DisposedITAT Delhi08 Mar 2024AY 2016-17

Bench: Dr. B. R. R. Kumarms. Astha Chandra

For Appellant: Sh. Amit Goel, CA &For Respondent: Ms. Sapna Bhatia, CIT-DR
Section 153ASection 69

fiction that in case any insurance, salvage or compensation money received in respect of the said property exceeds the difference between the written down value and the scrap value, so much of the excess as mentioned therein will be deemed to be the profits of the previous year in which

ACIT, CC-15, New Delhi vs. Yash Pal Mendiratta, Delhi

In the result, the appeals of the Revenue are dismissed and the Cross Objections of the assessees are also dismissed

ITA 1863/DEL/2021[2016-17]Status: DisposedITAT Delhi08 Mar 2024AY 2016-17

Bench: Dr. B. R. R. Kumarms. Astha Chandra

For Appellant: Sh. Amit Goel, CA &For Respondent: Ms. Sapna Bhatia, CIT-DR
Section 153ASection 69

fiction that in case any insurance, salvage or compensation money received in respect of the said property exceeds the difference between the written down value and the scrap value, so much of the excess as mentioned therein will be deemed to be the profits of the previous year in which

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

The appeal of the assessee is allowed and appeal of the revenue is dismissed

ITA 3811/DEL/2014[2009-10]Status: DisposedITAT Delhi05 Mar 2024AY 2009-10

Bench: Shri Saktijit Dey & Shri M. Balaganeshinternational Tractors Ltd, Vs. Dcit (Ltu), Sonalika House, 282, Nbcc Plaza, Pushp Agcr Enclave, Vihar, Sector-Iii, Karkardooma, Delhi- New Delhi 110092 (Appellant) (Respondent) Pan: Aaaci2270H Dcit (Ltu) International Tractors Ltd, New Delhi Sonalika House, 282, Agcr Enclave, Karkardooma, Delhi-110092 (Appellant) (Respondent) Pan: Aaaci2270H

For Appellant: Shri Mukesh Bhutani, AdvFor Respondent: Shri Anuj Garg, Sr. DR
Section 143(3)Section 14ASection 80J

incurrence of the said expenses. Since, the assessee had already claimed depreciation on the cost of dyes from AY 2008-09, the written down value of the cost of dyes (original cost less depreciation) was charged off to revenue expenditure as prior period expenses as per advice of the Chartered

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

The appeal of the assessee is allowed and appeal of the revenue is dismissed

ITA 3663/DEL/2014[2009-10]Status: DisposedITAT Delhi05 Mar 2024AY 2009-10

Bench: Shri Saktijit Dey & Shri M. Balaganeshinternational Tractors Ltd, Vs. Dcit (Ltu), Sonalika House, 282, Nbcc Plaza, Pushp Agcr Enclave, Vihar, Sector-Iii, Karkardooma, Delhi- New Delhi 110092 (Appellant) (Respondent) Pan: Aaaci2270H Dcit (Ltu) International Tractors Ltd, New Delhi Sonalika House, 282, Agcr Enclave, Karkardooma, Delhi-110092 (Appellant) (Respondent) Pan: Aaaci2270H

For Appellant: Shri Mukesh Bhutani, AdvFor Respondent: Shri Anuj Garg, Sr. DR
Section 143(3)Section 14ASection 80J

incurrence of the said expenses. Since, the assessee had already claimed depreciation on the cost of dyes from AY 2008-09, the written down value of the cost of dyes (original cost less depreciation) was charged off to revenue expenditure as prior period expenses as per advice of the Chartered

M/S. Prakash Industries Ltd, New Delhi vs. ACIT, Hisar

In the result, the appeal of the assessee in ITA No

ITA 1389/DEL/2014[2007-08]Status: DisposedITAT Delhi04 Mar 2024AY 2007-08

Bench: Shri N.K. Billaiya & Ms Astha Chandra

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Shri Vivek Vardhan, Sr. DR
Section 115JSection 143(3)Section 154Section 205(1)(b)Section 234B

only such sums as. emerge after the making of such a notional assessment for that year could be carried forward ; and the written down value as at the commencement, of the relevant previous year in respect of the assets then in existence for the current assessment year should remain ... relevant assessment year reducing the income to nil should be deemed to have been actually allowed for. the purpose of working' out the written down value for the immediately subsequent assessment year. In these circumstances, the amount of Rs. 83,61,301 written back to the profit and loss account

Nabros Transport Pvt. Ltd., Ahmedabad vs. The Assistant Commissioner of Income Tax, Circle-3(1)(1), Ahmedabad

In the result, appeal of the assessee is partly allowed for statistical purpose

ITA 559/AHD/2023[2016-17]Status: DisposedITAT Ahmedabad29 Feb 2024AY 2016-17

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2016-17

Section 133(6)Section 142(1)Section 143(1)Section 143(2)Section 234B

observed that as per depreciation chart forming part of return of income, the assessee claimed depreciation of Rs.1,69,996/- at 50% on written down value of Rs.3,39,999/- on vehicles categorised under Plant & Machinery. After taking cognisance of the assessee’s reply and details, the Assessing Officer disallowed

Addl CIT 8(1), Mumbai vs. M/S. Sanofi India Limited (Formerly Known As M/S. Aventis Pharma Ltd), Mumbai

In the result, the C.O. of the assessee for AY 2007-08 is partly allowed

ITA 6698/MUM/2011[2007-08]Status: DisposedITAT Mumbai23 Feb 2024AY 2007-08

Bench: Shri Vikas Awasthy, Jm & Ms Padmavathy S, Am

For Respondent: Shri Ajay Chandra (CIT-DR) &
Section 32Section 32(1)

appreciating the fact that the depreciation under the Income Tax Act is claimed on the "Block of Assets" and not based on the Written Down Value (WDV) of the 6698 M 2011 & C.O. No. 165 M 2012-Sanofi India Limited assets. The ld. AR drew our attention to the decision