“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

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

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

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

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

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

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

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

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

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)

received Government grants during the relevant 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 ... only be made in that year. Once the asset forms part of the block of assets, it loses its individual identity and the written down value of the block can only be adjusted in accordance with section 43(6)(c), which permits adjustments only for additions and disposals during

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)

which precisely includes an insurance claim in respect of a building, machinery, plant or furniture and thus can be deducted for computing Written Down Value (WDV) as per provisions of section 43(6) of the Act: 9 erred in relying and misinterpreting decision of Hon'ble Supreme Court in case ... further submitted that as per the provisions of section 43(6)(C)(i)(B) r.w. Explanation-4 for computation of Written Down Value for 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

Ideaforge Technology Ltd, Mahape vs. ACIT, Circle 15(2)(1), Mumbai

The appeal of the assessee is allowed

ITA 867/MUM/2025[2017-18]Status: DisposedITAT Mumbai26 Sept 2025AY 2017-18

Bench: Shri Narender Kumar Choudhry & Smt. Renu Jauhriआयकर अपील सं./Ita No. 867/Mum/2025 (निर्धारण वर्ा / Assessment Year: 2017-18) Ideaforge Technology V/S. Assistant Commissioner Ltd. बिधम Of Income Tax, Circle El-146, Ttc Industrial 15(2)(1), Mumbai Area, Electronic Zone, Room No. 357, 3Rd Floor, Midc, Mahape, Navi Aayakar Bhavan, Maharshi Mumbai Karve Road, Mumbai 400020 स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No: Aabci6495B Appellant/अपीलधथी .. Respondent/प्रनिवधदी निर्धाररिी की ओर से /Assessee By: Shri Subodh Ratnaparkhi Shri. Leyaqat Ali Aafaqui (Sr Dr) रधजस्व की ओर से /Revenue By: सुिवधई की िधरीख / Date Of Hearing 22.08.2025 घोर्णध की िधरीख/Date Of Pronouncement 26.09.2025 आदेश / O R D E R Per Renu Jauhri [A.M.] :- This Appeal Is Filed By The Assessee Against The Order Of The National Faceless Appeal Centre (Nfac), Delhi [Cit(A)] Dated 11.12.2024, Passed U/S. 250 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “Act”] For Assessment Year [A.Y.] 2017-18. 2. The Assessee Has Raised The Following Grounds Of Appeal: “On The Facts & In Law, 1. The Hon. Cit(A) Erred In Upholding The Action Of The Id Ao In Making Addition Of Rs. 6,60,02,100/- By Relying Upon The Provisions Of Section 56(2)(Viib) Of The It Act, 1961 On The Ground That The Consideration Received By The Appellant For Issue Of P A G E | 2

For Appellant: Shri Subodh Ratnaparkhi

Section 143(3)Section 250Section 56(2)(viIb)Section 56(2)(viib)

only one difference. It was submitted that the assessee following the Explanation-2 below section 50B(3) of the Act has adopted written down value of the block asset in case of the depreciable asset as per the proviso to section 43 of the Act, which the AO has omitted

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

purposes of business or profession, the deduction in respect of such asset shall be allowed on such percentage on the written down value thereof as may be prescribed…” Page 6 of 19 ITA Nos. 3103 & 6906/Del/2019 7.0 The first question that deserves to be considered in the matter

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

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

exceeds the aggregate of the following amounts, namely:- (i) expenditure incurred wholly and exclusively in connection with such transfer or transfers; (ii) the written down value of the block of assets at the beginning of the previous year; and (iii) the actual cost of any asset falling within the block ... assets in that block are transferred during the previous year, the cost of acquisition of the block of assets shall be the written down value of the block of assets at the beginning of the previous year, as increased by the actual cost of any asset falling within that block

DCIT Central Circle 3(2), Mumbai, Air India vs. Aarti Industries Limited, Mumbai

In the result, the appeal is dismissed

ITA 4869/MUM/2023[2015-2016]Status: DisposedITAT Mumbai25 Sept 2025AY 2015-2016

Bench: Shri Saktijit Dey & Shri Girish Agrawaldy. Cit, Central Circle-3(2) Aarti Industries Limited R. No. 1913, 19Th Floor, 71, Udyog Kshetra, 2Nd Floor, Air India Building, Nariman Point, Vs. Mulund Goregaon Link Road, Mumbai-400 021 Mulund (W), Mumbai-400 080 Pan/Gir No. Aabca 2787 L (Appellant) : (Respondent) Appellant By : Shri Vijay Mehta Respondent By : Shri Rajesh Kumar Yadav Date Of Hearing : 12.08.2025 Date Of Pronouncement : 25.09.2025 O R D E R Per Saktijit Dey: This Is An Appeal By The Revenue, Against The Order Dated 30.10.2023 Of Learned Commissioner Of Income Tax (Appeals), Mumbai (‘Ld.Cit(A) For Short), Pertaining To The Assessment Year (A.Y.) 2015-16. 2. Ground No. 1 In The Appeal Reads As Under: 1. On The Facts & Circumstances Of The Case, The Ld. Cit(A) Erred In Deleting The Disallowances Made By The A.O. To Restrict The Deduction U/S. 80Ia Of The Act Despite The Fact That The Issue Has Not Attained Finality & Pending For Adjudication Before The Hon'Ble Supreme Court? – Rs.396,81,798/- 3. Briefly The Facts Are, The Assessee Is A Resident Corporate Entity Engaged In Manufacturing & Sale Of Chemicals, Fertilizers & Intermediaries. For Such Manufacturing Activity, The Assessee Has Set Up A Plant At Plot No. 801/23, Gidc, Phase-Iii

For Appellant: Shri Vijay MehtaFor Respondent: Shri Rajesh Kumar Yadav

Section 133(6)Section 80I

factual inaccuracy or confusion is there in the order of the authorities below. The assessee is granted depreciation allowance on the opening written down value (WDV) arising out of the foreign exchange difference of loans actually repaid. The depreciation allowance has been granted by the Assessing Officer himself in earlier

Assistant Commissioner of Income Tax, Circle-2.1.1, Vejalpur vs. Mundra International Container Terminal Pvt. Ltd., Kutch

In the result, the grounds raised by the Revenue for AYs 2017-18 and 2018-19 are dismissed

ITA 1268/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad24 Sept 2025AY 2018-19

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalmundra International Container Dcit, Vs. Terminal Private Limited, Circle 2(1)(1), Navinal, New Mundra Port, Post Ahmedabad Box No.8, Mundra, Kutch [Pan : Aadca 0917 C]

For Appellant: Shri S.N. Soparkar, Sr. AdvocateFor Respondent: Shri R.P. Rastogi, CIT-DR

Section 115Section 14ASection 250Section 80I

sides and perused the material on record. The assessee has claimed depreciation of Rs. 10,13,23,469/- on infrastructure usages facility on written down value of Rs. 405,23,93,877/- treating the same as intangible asset. The assessee company was using infrastructure facility developed by Mundra Port

Assistant Commissioner of Income Tax, Vejalpur vs. Mundra International Container Terminal Pvt. Ltd., Kachchh

In the result, the grounds raised by the Revenue for AYs 2017-18 and 2018-19 are dismissed

ITA 1261/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad24 Sept 2025AY 2017-18

For Appellant: Shri S.N. Soparkar, Sr. AdvocateFor Respondent: Shri R.P. Rastogi, CIT-DR

Section 115Section 14ASection 250Section 80I

Mundra International Container Terminal Private Limited, Mundra vs. The Deputy Commissioner of Income-Tax, Ahmedabad

In the result, the grounds raised by the Revenue for AYs 2017-18 and 2018-19 are dismissed

ITA 1241/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad24 Sept 2025AY 2017-18

For Appellant: Shri S.N. Soparkar, Sr. AdvocateFor Respondent: Shri R.P. Rastogi, CIT-DR

Section 115Section 14ASection 250Section 80I

Deluxe Recycling India Private Limited, Mumbai vs. Circle 4(1)(1), Mumbai

In the result, appeal of the assessee is allowed for statistical purposes

ITA 2046/MUM/2025[2020-21]Status: DisposedITAT Mumbai22 Sept 2025AY 2020-21

Bench: Shri Sandeep Gosain & Shri Girish Agrawalassessment Year: 2020-21 Assistant Commissioner Of Deluxe Recycling India Income Tax-4(1)(1), Private Limited Mumbai 13 17 Dady Sheth Agiary Vs. Lane, Kalbadevi Road, Kalbadevi, Mumbai-400002 (Pan: Aaacd8909N) (Appellant) (Respondent) Assessment Year: 2020-21 Deluxe Recycling India Private Assistant Commissioner Of Limited Income Tax-4(1)(1), 13 17 Dady Sheth Agiary Lane, Mumbai Vs. Kalbadevi Road, Kalbadevi, Mumbai-400002 (Pan: Aaacd8909N) (Appellant) (Respondent)

For Appellant: Shri Rahul Hakani, AdvocateFor Respondent: Shri Annavaram Kosuri, Sr. DR

Section 143(3)Section 32Section 40A(2)(b)Section 56Section 56(2)(x)

flat has been sold in AY 2023-24. While reporting capital gain on this transaction in AY 2023-24, assessee has taken the Written Down Value (WDV) at a lower figure, i.e., after the claim of depreciation in the year under consideration which has been accepted by the Department

Assistant Commissioner of Income Tax-4(1)(1), Mumbai vs. Deluxe Recycling India Private Limited, Mumbai

In the result, appeal of the assessee is allowed for statistical purposes

ITA 1969/MUM/2025[2020-21]Status: DisposedITAT Mumbai22 Sept 2025AY 2020-21

For Appellant: Shri Rahul Hakani, AdvocateFor Respondent: Shri Annavaram Kosuri, Sr. DR

Section 143(3)Section 32Section 40A(2)(b)Section 56Section 56(2)(x)

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

short ‘the Act’). The case of the assessee was selected for complete scrutiny through CASS with the reasons “Opening Written Down Value of fixed assets as per ITR of current year is greater than closing Written Down Value of fixed assets as per ITR of preceding year; Large “any other

Gsp Crop Science Limited, Ahmedabad vs. The Pr.CIT-1, Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 987/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad18 Sept 2025AY 2020-21

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Mehul K. Patel, ARFor Respondent: Shri Rignesh Das, CIT- DR

Section 135Section 143(3)Section 144BSection 263Section 35Section 37(1)Section 40Section 80G

previous year’s assets put to use for less than 180 days. However, the A.O. failed to adjust this from the opening written down value (WDV) before computing the normal depreciation. This led to an excess depreciation claim of Rs. 1,80,783/-, which the Pr. CIT held as irregular

Smt Bertha D'Costa, Cavelossim, Goa vs. Income Tax Officer, Ward -2, Margao

In the result, the appeal filed by the assessee is partly allowed

ITA 159/PAN/2019[2015-16]Status: DisposedITAT Panaji15 Sept 2025AY 2015-16

Bench: Shri Pavan Kumar Gadalei T A. Nos.158 &159/Pan/2019 (A.Y. 2015-16 ) Shri.Julio D Costa, Vs Ito-Ward-2, H.No.337,Mobor,Cavelossim, Blessings Pioneer Salcete,Goa-403731. Complex, (Pan:Aewpd6709F) Old Market, Margoa-403601,Goa. Smt.Bertha D Costa, Ito-Ward-2, Vs H.No.337,Mobor,Cavelossim, Blessings Pioneer Salcete,Goa-403731. . Complex, (Pan:Aewpd6748N) Old Market, Margoa-403601,Goa. (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Shri.Shrinivas Nayak.Ar Revenue By Smt.Manju Thakur.Sr.Dr सुनवाई की तारीख/Date Of Hearing 09.09.2025 घोषणा की तारीख/Date Of Pronouncement 15.09.2025 Order Per Pavan Kumar Gadale, Jm: These Two Appeals Are Filed By The Assesses (Husband & Wife) Against The Separate Orders Of The Cit(A) -1 Panaji Passed U/Sec143(3) & U/Sec 250 Of The Act. The Assesses Are Governed By The Portuguese Civil Code & Provisions Of Section 5A Of The Act. 2. Since The Issues Involved In These Two Appeals Are Common & Identical, Hence They Are Clubbed, Heard & Aconsolidated Order Is Passed. For The Sake Of Convenience

Section 44ASection 5A

under –Fixed Assets-Trawler2 with the cost/purchase value of Rs.60,00,000/- and claimed the depreciation@20% i.e.Rs.12,00,000/- and the Written down value(WDV) of Rs.48,00,000/- was reflected and the balance sheet is placed at Page 10 of the paper book. The Ld.AR also submitted

Shri Julio D'Costa, Cavelosim, Goa vs. Income Tax Officer, Ward -2, Margao

In the result, the appeal filed by the assessee is partly allowed

ITA 158/PAN/2019[2015-16]Status: DisposedITAT Panaji15 Sept 2025AY 2015-16

Section 44ASection 5A

H & M Housing Finance and Leasing Private Limited, Mumbai vs. The Deputy Commissioner of Income Tax, Circle 7(1)(2), Mumbai

In the result, ground No. 1 and 2 of the assessee‟s appeal is allowed

ITA 1332/MUM/2024[2017-18]Status: DisposedITAT Mumbai15 Sept 2025AY 2017-18

Bench: Shri Vikram Singh Yadav & Shri Raj Kumar Chauhanassessment Year : 2017-18 H&M Housing Finance & Deputy Commissioner Of Leasing Private Limited, Income Tax, C/62, 9Th Floor, Vibgyor Towers, Vs. Circle–7(1)(2), Bandra Kurla Complex, Aayakar Bhavan, Bandra (East), M.K.Road, Mumbai-400051. Mumbai-400020. Pan : Aabch4398E (Appellant) (Respondent) Assessee By : Shri Nitesh Joshi & Shri Nishith Khatri Revenue By : Shri Hemanshu Joshi, Sr.Dr

For Appellant: Shri Nitesh Joshi and Shri Nishith KhatriFor Respondent: Shri Hemanshu Joshi, Sr.DR

Investment Limited, the ld CIT(A) has upheld the assessment as profits and gains of business. With respect to the alternative ground of written down value on which depreciation is to be allowed for the year under consideration, the Ld.CIT(A) has held that “the building has been ... since the year 2005-06 and the written down value has to be computed after allowing depreciation commencing from the said year.” Aggrieved by the aforesaid findings of the Ld.CIT(A), the assessee has filed the present appeal before the Tribunal. 7. In light of aforesaid factual matrix

Eagle Fashions Private Limited, Surat vs. DCIT Circle 1(1)(1), Surat

The appeal of the assessee is treated as allowed for statistical purposes

ITA 1252/SRT/2024[2011-12]Status: DisposedITAT Surat12 Sept 2025AY 2011-12

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं /Ita No.1252/Srt/2024 िनधा"रण वष" /Assessment Year : 2011-12 Eagle Fashions Private The Deputy Director Of Income Limited, 201, 2Nd Floor बनाम/ Tax, Cpc, Bengaluru Orleaans Building Current Jurisdiction: V/S. Near City Centre Deputy Cit Sosyo Circle, Magdalla Circle-1(1)(1), Surat Bharthana B.O., Surat "थायी लेखा सं./Pan: Aaace 5107 F (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Rasesh Shah, Ca Revenue By : Shri Ajay Uke, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 19/06/2025 घोषणा की तारीख /Date Of Pronouncement: 12/09/2025 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Office Of The Commissioner Of Income Tax, Appeal, Addl/Jcit (A), Prayagraj [Hereinafter Referred To As ‘Ld.Cit(A)’] Dated 30/09/2024 For Assessment Year (Ay) 2011-12. The Assessee Is Aggrieved By The Action Of The Ld.Cit(A) In Dismissing The Appeal Of The Assessee Holding The Same As Time- Barred. Eagle Fashions Private Limited Vs. Dcit Asst. Year : 2011-12

For Appellant: Shri Rasesh Shah, CAFor Respondent: Shri Ajay Uke, Sr.DR

Section 143(1)Section 154Section 250

return of income on 25.09.2011 showing total income of Rs.17,72.659/-. In the schedule 'DOA' of ITR Form, assessee had shown the opening written down value of land & building at Rs. 3,25,295/- as against same shown in preceding previous year at Rs. 33,59,795/-Further, in case ... furniture, assessee had shown the opening written down value at Rs.NIL as against the same shown in preceding previous year at Rs.79,528/-. So, there was a total difference of Rs.21,14,028/-. In the return of income assessee had shown capital gain of Rs.2,45,918/-. However, assessing officer

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)

case where a subsidiary Indian company has acquired a capital asset from its parent company falling under this clause (iv) of Sec.47, the written down value of transferred capital asset to the subsidiary company would be taken to be the same as it would have been if the parent company