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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

Hewlett Packard Financial Services (India) P. Ltd, Bangalore vs. Asst CIT Cir 2(1)(2), Bangaluru

Accordingly, the ground is dismissed as not pressed

ITA 915/MUM/2017[2011-12]Status: DisposedITAT Mumbai21 Oct 2025AY 2011-12

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am

Section 115JSection 143(3)Section 250Section 41

without prejudice made an alternate claim that in case the unabsorbed depreciation is not allowed to be carry forwards then the written down value of the asset should be increased to that extent. The ld. AR further submitted that by denying the carry forward of unabsorbed depreciation and by reducing ... submitted that if its returns and claim of depreciation made therein is not considered then he should be allowed to increase its written down value for the current year to that extent. This plea of the assessee is also not acceptable as allowing the same would amount to allowing

Assistant Commissioner of Income Tax, Circle-1(1), Tirupati vs. Venkata Swamy Ravuri, Chittoor

In the result, the appeal of the Revenue is allowed for

ITA 257/HYD/2022[2017-18]Status: DisposedITAT Hyderabad17 Oct 2025AY 2017-18

Bench: Shri Vijay Pal Rao, Vice- & Shri Madhusudan Sawdia

For Appellant: Advocate Sashank Dundu
Section 143(3)Section 2Section 68

fixed asset schedule placed at page no. 27 of the paper book. The Ld. AO, after verifying the sale consideration and written down value of the building, made the addition. However, the Ld. CIT(A) deleted the same by accepting the assessee’s explanation that the gain was not taxable

Gujarat Energy Development Agency, Gandhinagar vs. The Dy.CIT, Circle-1, Exemp, Ahmedabad

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

ITA 1180/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad16 Oct 2025AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

Section 11Section 12ASection 143(3)Section 263Section 270A

wind farm and disposal of the non-performing assets. The Ld. AR submitted that as per the certificate of the Chartered Accountant, the written down value of the non-performing assets was assessed to ‘zero’, and, therefore, an amount of Rs.9,35,16,377/- was debited to the Income & Expenditure ... depreciation could have been claimed thereon. The Ld. CIT-DR submitted that as per the provisions of the Act, the balance written down value of the assets was required to be adjusted with the “block of assets” for the purpose of computation of income as per the provisions

Gujarat Energy Development Agency, Gandhinagar vs. The Dy.CIT, Circle-1, Exemp, Ahmedabad

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

ITA 1179/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad16 Oct 2025AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

Section 11Section 12ASection 143(3)Section 263Section 270A

wind farm and disposal of the non-performing assets. The Ld. AR submitted that as per the certificate of the Chartered Accountant, the written down value of the non-performing assets was assessed to ‘zero’, and, therefore, an amount of Rs.9,35,16,377/- was debited to the Income & Expenditure ... depreciation could have been claimed thereon. The Ld. CIT-DR submitted that as per the provisions of the Act, the balance written down value of the assets was required to be adjusted with the “block of assets” for the purpose of computation of income as per the provisions

Altera Digital Health (India) LLP (Formerly Known As Allscripts (India) LLP), Vadodara vs. The Dy.CIT, Circle-1(1)(1), Vadodara

In the result, Ground Number 11 of the assessee’s appeal is allowed for statistical purposes

ITA 359/AHD/2022[2018-19]Status: DisposedITAT Ahmedabad15 Oct 2025AY 2018-19

Bench: Smt. Annapurna Gupta (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

Section 92C(1)

upward adjustment of Rs. 3,94,09,319/- was proposed. Another issue examined during the scrutiny was the substantial mismatch between the closing written down value (WDV) of assets in the preceding year and the opening WDV in the current year. The assessee submitted that the difference arose on account

Assistant Commissioner of Income Tax-16(1), Mumbai vs. Viacom18 Media Private Limited, Mumbai

ITA 5658/MUM/2024[2013-14]Status: DisposedITAT Mumbai15 Oct 2025AY 2013-14

Bench: Shri Narender Kumar Choudhry & Ms. Padmavathy S

For Respondent: Shri Nimesh Vora, Ld. Adv
Section 115JSection 143(1)Section 143(2)Section 143(3)Section 250

compete fee” we observe from the assessment order that in the scheme of demerger, intangible asset by name of non-compete fee @ Written Down Value (WDV) of Rs. 329,76,56,250/- was distributed among ETPL, PTVPL and PTPL. The Assessee accordingly has acquired intangible asset in the name ... No.3 which pertains to the disallowance of depreciation of Rs.10,13,96,329/- claimed on 'Film Software Library'. The Assessee has shown opening Written Down Value (WDV) of 'Film Software Library' as on 01/04/2012 at Rs. 54,29,62,024/- from the business activities of satellite television broadcasting and claimed

Reliance Power Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle 15(3)(1), Mumbai

In the result, ground of appeal raised by assessee is allowed

ITA 1348/MUM/2023[2013-2014]Status: DisposedITAT Mumbai14 Oct 2025AY 2013-2014

Bench: Shri Pawan Singh& Shri Omkareshwar Chidara(Physical Hearing) Dcit – 15(3)(1), Mumbai Reliance Power Limited Room No. 460, 4Th Floor, H-Block, 1St Floor, Dhirubhai Ambani Vs Aayakar Bhavan, M.K. Road, Knowledge City, Koperkhairane, Mumbai – 400020] Navi Mumbai-400710 [Pan: Aaacr2365L] Appellant / Revenue Respondent / Assessee Reliance Power Limited Dcit – 15(3)(1), Mumbai Room No. 460, 4Th Floor, Aayakar Reliance Centre, Ground Floor, 19 Vs Walchand Hirachand Marg, Bhavan, M.K. Road, Ballard Estate, Mumbai – 400001. Mumbai – 400020] [Pan: Aaacr2365L] Appellant / Assessee Respondent / Revenue

Section 14ASection 254(1)Section 50

Reliance Natural Resources Ltd (RNRL) on demerger during F.Y. 2010-11. The helicopter was sold during the year for Rs. 8.84 crores. The written down value of this block of asset was of Rs. 25.34 lakhs. The differential value of ITA Nos. 890 1348/Mum/2023 & C.O. 71/Mum/2023 Reliance Power ... acquired from Reliance Natural Resources Ltd.(RNRL) on demerger during F.Y. 2010-11 and is sold during the year under consideration. The written down value of block of asset was Rs. 25.34 lakhs, thus, differential amount of Rs. 858.96 lakhs has been treated as capital gain by assessing officer

Mdr Cranes & Infrastructure Pvt Ltd, Visakhapatnam vs. Assistant Commissioner of Income Tax, Circle-3(1), Visakhapatnam

In the result, appeal of the assessee is dismissed

ITA 208/VIZ/2024[2014-15]Status: DisposedITAT Visakhapatnam13 Oct 2025AY 2014-15

Bench: Shri Ravish Sood, Hon’Ble

Section 143(2)Section 143(3)

that due to defaults of loans taken by the Company the financiers seized the certain machinery kept as security which was having a Written Down Value (WDV) in the books of accounts as on 01.04.2013 at Rs.7,24,84,687/-. Ld.AO further observed that assessee has reduced the value

Franklin Templeton Internaitoanl Services (I) P.Ltd, Mumbai vs. DCIT (OSD) 3(1), Mumbai

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

ITA 7216/MUM/2012[2008-09]Status: DisposedITAT Mumbai13 Oct 2025AY 2008-09

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

Section 133(6)Section 92D

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, Plant and Machinery and Building, consequent to disallowance of revenue expenditure

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

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, Plant and Machinery and Building, consequent to disallowance of revenue expenditure

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)

definition of intangible assets. ➤ Section 43(6) (c) (ii): Definition of WDV of the block of assets has been amended to provide that written down value of Goodwill is required to be reduced from the Opening WDV in such cases, where the Goodwill is already forming part of Block ... amended to provide that where goodwill forms part of block of asset for assessment year 2020-21 and depreciation has been claimed, the written down value of the block and short-term capital gains would be determined in the prescribed manner. Rule 8AC has been prescribed for this purpose. ➤ Section

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

with these promotional methods. 13.2 Secondly, it is an admitted fact that these cars formed part of the block of assets and their written down value (WDV) has been carried forward from earlier years. Once an asset is part of a block, depreciation is allowable on the block ... amended section 32, deduction is to be allowed - "In the case of any block of assets, such percentage on the written down value thereof as may be prescribed". Thus, the depreciation is allowed on block of assets, and the revenue cannot segregate a particular asset therefrom on the ground that

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

IN THE INCOME TAX APPELLATE TRIBUNAL 'A' BENCH, BANGALORE BEFORE SHRI NARENDER KUMAR CHODHRY, JUDICIAL MEMBER AND SHRI WASEEM AHMED

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

IN THE INCOME TAX APPELLATE TRIBUNAL 'A' BENCH, BANGALORE BEFORE SHRI NARENDER KUMAR CHODHRY, JUDICIAL MEMBER AND SHRI WASEEM AHMED

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

IN THE INCOME TAX APPELLATE TRIBUNAL 'A' BENCH, BANGALORE BEFORE SHRI NARENDER KUMAR CHODHRY, JUDICIAL MEMBER AND SHRI WASEEM AHMED

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

with these promotional methods. 13.2 Secondly, it is an admitted fact that these cars formed part of the block of assets and their written down value (WDV) has been carried forward from earlier years. Once an asset is part of a block, depreciation is allowable on the block ... amended section 32, deduction is to be allowed - "In the case of any block of assets, such percentage on the written down value thereof as may be prescribed". Thus, the depreciation is allowed on block of assets, and the revenue cannot segregate a particular asset therefrom on the ground that

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

IN THE INCOME TAX APPELLATE TRIBUNAL 'A' BENCH, BANGALORE BEFORE SHRI NARENDER KUMAR CHODHRY, JUDICIAL MEMBER AND SHRI WASEEM AHMED

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

assessee company on 03.02.2017. On 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 ... under: 4. In respect of the claim of depreciation, the assessee had added the unabsorbed depreciation of the amalgamating company to the written down value and claimed depreciation on the resultant amount. The Assessing Officer allowed depreciation only on the written down value and not on the value enhanced

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

section 801A of the Act: 9.1 The learned PCIT has erred in facts in holding that there has been an excess claim of Written Down Value ("WDV") of assets to the extent of INR 56,78,75,869 in the revised ROI filed by VITP for the subject AY without ... assessee company on 03.02.2017. On 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

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

good- will. 9. 1. This means that during the year under consideration, the assessee has claimed depreciation on good-will on the written down value brought forward from earlier year. The Hon'ble Bombay High Court in the case of DIT (IT) vs. HSBC Asset Management ... under Section 143(3) dated 28.03.2006. The 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