“opening WDV”

DepreciationSection 43(6)Section 43(6)263 judgments

The decision most relied on for opening WDV is ACIT v. Progressive Constructions Ltd. (92 Taxmann.com 104), cited in 63 judgments on BharatTax.

Leading authorities on opening WDV

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.

CIT v. Artex Manufacturing Co.

227 ITR 260 · 1997 · Supreme Court

citing judgments

In a slump sale, the slump purchase price cannot be apportioned among individual assets for claiming depreciation, as there is no indication of the price attributable to specific assets out of the total sale consideration.

DCIT v. Toyo Engineering India ltd.

33 Taxmann.com 560 · 2013 · Reported

citing judgments

Depreciation is not allowed on goodwill if it arises from book entries and has no identifiable cost of acquisition. This applies even when goodwill is acquired as part of a scheme of arrangement or amalgamation.

Bodal Chemicals Ltd. v. ACIT, Ahmedabad

112 Taxmann.com 217 · 2019 · ITAT

citing judgments

Once depreciation on an asset is allowed in the first year, the revenue is debarred from denying depreciation on the written-down value carried forward in subsequent years, absent a change in facts or law.

PCIT v. GVK Jaipur Expressway

100 Taxmann.com 96 · 2018 · Supreme Court

citing judgments

The Supreme Court has affirmed that developers of roadways, operating on a Build-Operate-Transfer (BOT) basis, are eligible to claim depreciation on the roads constructed. This decision supports the assessee's claim against the Revenue's challenge.

Judgments citing opening WDV

Edgeverve Systems Limited, Bangalore vs. ACIT, Circle-2(2)(1), Bangalore

In the result, both the appeals of the assessee are partly allowed for statistical purposes

ITA 292/BANG/2025[2019-20]Status: DisposedITAT Bangalore30 Jan 2026AY 2019-20

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Padamchand Kincha, CAFor Respondent: Shri Shivanad Kalakeri, CIT (DR)

Section 250Section 254Section 37Section 90

section 32 of the Act from F.Y. 2014-15 relevant to A.Y. 2015-16 till the year under consideration in the following manner: A.Y. Opening WDV Addition Total assets Depreciation Closing WDV (Rs.) during the (Rs.) at 25% (Rs.) (Rs.) year

Edgeverve Systems Limited, Bangalore vs. ACIT, Circle-2(2)(1), Bangalore

ITA 291/BANG/2025[2018-19]Status: DisposedITAT Bangalore30 Jan 2026AY 2018-19

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Padamchand Kincha, CAFor Respondent: Shri Shivanad Kalakeri, CIT (DR)

Section 250Section 254Section 37Section 90

from F.Y. 2014-15 relevant to A.Y. 2015-16 till the year under consideration in the following manner: Α.Υ. Opening WDV (Rs.) Addition during the year (Rs.) Total assets (Rs.) Depreciation at 25% (Rs.) Closing WDV

Edgeverve Systems Limited, Bangalore vs. ACIT, Circle-2(2)(1), Bangalore

In the result, both the appeals of the assessee are partly allowed for statistical purposes

ITA 290/BANG/2025[2017-18]Status: DisposedITAT Bangalore30 Jan 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Padamchand Kincha, CAFor Respondent: Shri Shivanad Kalakeri, CIT (DR)

Section 250Section 254Section 37Section 90

Salgaocar Mining Industries Pvt. Ltd, Panaji vs. Deputy Commissioner of Income Tax, Circle - 1, Margao

The appeal of the assessee is PARTLY ALLOWED in aforestated terms

ITA 132/PAN/2025[2006-07]Status: DisposedITAT Panaji29 Jan 2026AY 2006-07

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliassessment Years: 2006-2007 M/S Salgaocar Mining Industries Pvt Ltd. Salgaonkar Bhava, Altino, Panaji, Goa-403001. Pan: Aabcs8862N . . . . . . . Appellant V/S Dy. Commissioner Of Income Tax, Circle-1, Margao, Goa. . . . . . . . Respondent Represented Assessee By: Mr Sukhsagar Syal [‘Ld. Ar’] Revenue By: Ms Rijjula Uniyal [‘Ld. Dr’] Date Of Conclusive Hearing : 20/01/2026 Date Of Pronouncement : 29/01/2026 Order Per G. D. Padmahshali; This Assessee’S Appeal Filed U/S 253(1) Of The Income- Tax Act, 1961 [‘The Act’] Impugns The Order Dt. 20/03/2025 Passed U/S 250 Of The Act By Commissioner Of Income Tax(Appeals-2), Panaji [‘Ld. Cit(A)’] Which In Turn Dealt With Order Dt. 20/12/2011 Passed U/S 144 Of The Act By Dcit, Circle-1, Margao Goa [‘Ld. Ao’] Anent To Assessment Year 2006-07.[‘Ay’]

For Appellant: Mr Sukhsagar Syal [‘Ld. AR’]For Respondent: Ms Rijjula Uniyal [‘Ld. DR’]

Section 143(1)Section 143(2)Section 143(3)Section 144Section 147Section 148Section 154Section 246ASection 250Section 253(1)

Salgaocar Shipping Co. Pvt. Ltd., and (2) ₹1,82,643/- excess depreciation claimed on block of ship owning to incorrect b/f of opening WDV etc. We further note that, in first appellate proceedings the appellant tried to explain the difference with reference to audited financial statement, but for the want

Amit Bholanath Mishra, Mumbai vs. Assistant Commissioner of Income Tax, Circle - 22(1), Mumbai

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

ITA 7219/MUM/2025[2016-17]Status: DisposedITAT Mumbai19 Jan 2026AY 2016-17

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokaramit Bholanath Mishra Acit Circle 22(1), 502, Heena Elegance, Piramal Chamber, Saibaba Nagar, Borivali Vs. Lal Baug, Parel, (West), Mumbai-400 092 Mumbai-400 012 Pan/Gir No. Aampm3121G (Applicant) (Respondent) Assessee By Shri Rakesh Joshi, Ld. Ar Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 14.01.2026 Date Of Pronouncement 19.01.2026

Section 143(3)Section 250Section 271(1)(c)Section 50Section 70

Assessing Officer insofar as the rate of depreciation at 30 percent was concerned and also upheld the re- computation of depreciation and opening WDV by invoking the provisions of Explanation 6 to section 43(6) of the Act. However, 5 Amit Bholanath Mishra the CIT(A) accepted the assessee ... erred in confirming the action of the Learned Assessing Officer in recalculating depreciation of car in earlier years @ 30% and re-computing opening WDV without assigning any reason and rework & recalculated depreciation from AY 2012-13 to 2015- 16, without considering the facts and circumstances of the case

Reliance Retail Limited, Mumbai vs. Assistant Commissioner of Income Tax, Circle 8(1)(1), Mumbai

In the result, the appeal of the Assessee is allowed

ITA 3509/MUM/2025[2021-22]Status: DisposedITAT Mumbai12 Jan 2026AY 2021-22

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

Section 143(3)Section 194C

PCIT, the assets should have been capitalized in the earlier assessment year and depreciation should have been accordingly allowed to reduce value of opening WDV. 9.1 In response the Assessee submitted that during the course of the assessment proceeding the AO called for the details in respect of such addition

JCIT(OSD) Range-10, New Delhi, ITO, C.R. Building vs. Gwalior Bypass Project Ltd., New Ashok Nagar, Delhi

In the result, the appeal of the revenue is dismissed

ITA 2896/DEL/2025[2016-17]Status: DisposedITAT Delhi07 Jan 2026AY 2016-17

Bench: Shri C. N. Prasad & Shri M. Balaganeshjcit(Osd), Vs. Gwalior Bypass Project Ltd, Range-10, New Delhi B-292, Chandrakanta Complex, Shop No. 2 & 3, Near Metro Pillar No. 161, New Ashok Nagar, New Delhi (Appellant) (Respondent) Pan: Aaccg6312J

For Appellant: Ms. Chinu Bhasin, AdvFor Respondent: Ms. Pooja Swaroop, CIT (DR)

Section 143(3)Section 32

1297/Del/2019 dated 26-07-2022. We find that the Assessee during the year had claimed depreciation on Highway projects on the opening WDV and that the depreciation had been duly allowed by this Tribunal in earlier two assessment years which Tribunal order has been followed by the Learned CITA while

Jewelex India Priavte Limited, Mumbai vs. DCIT Circle-14(1)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 5285/MUM/2025[2020-21]Status: DisposedITAT Mumbai05 Jan 2026AY 2020-21

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarjewelex India Private V/S. Deputy Commissioner Of Limited बनाम Income Tax, Circle – 401 Trade Centre, Bandra 14(1)(1), Aayakar Bhavan, Kurla Complex, Bandra Maharishi Karve Marg, (East), Mumbai – 400 098, Mumbai – 400 020, Maharashtra Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aabcj4523H Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Nitesh Joshi, ARFor Respondent: Ms. Kavitha Kaushik, (Sr. DR)

Section 135Section 143(3)Section 37Section 37(1)Section 43(6)(c)Section 80G

assets, consisting building, the actual sale consideration in respect of an asset sold from the block of the asset should be reduced from opening WDV, whereas according to the Revenue, the notional sale consideration of the asset sold as prescribed u/s. 50C should be reduced from opening WDV. In view

Divjyot Chemicals Private Limited, K.V. Rangareddy vs. ITO., Ward-17(1), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 948/HYD/2025[2016-17]Status: DisposedITAT Hyderabad19 Dec 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: Shri Y V Bhanu Narayan Rao, C.AFor Respondent: Smt. B K Vishnu Priya, SR-DR

Section 144Section 156Section 250Section 271(1)(c)Section 50

sale of depreciable assets and states that when the net sale consideration on the sale of asset is reduced from the written down value (opening WDV + cost of assets acquired if any) of the block of the assets and the written down value of the said block of asset

Deputy Commssioner of Income Tax, Central Circle, 4(3), Kolkata vs. Privi Exports Private Limited, Kolkata

In the result, the appeal filed by the revenue is dismissed and cross-objection of the assessee is allowed for statistical purposes

ITA 1605/KOL/2025[2018-19]Status: DisposedITAT Kolkata12 Dec 2025AY 2018-19

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2018-19 Dcit, Central Circle-4(3), Kolkata…..……………….……….……….……Appellant Vs. Privi Exports Pvt. Ltd….………………………………….....……...…..…..Respondent Office No.2, Gf, 91A/1, Park Street, Kol-16. [Pan: Aaicp6253B] C.O. No.67/Kol/2025 (In Ita No.1605/Kol/2025) Assessment Year: 2018-19 Privi Exports Pvt. Ltd.….……………………. ….……….……….……Cross-Objector Office No.2, Gf, 91A/1, Park Street, Kol-16. [Pan: Aaicp6253B] Vs. Dcit, Central Circle-4(3), Kolkata...…………………....…..…………….Respondent Appearances By: Shri Manish Tiwari, Fca, Appeared On Behalf Of The Assessee. Shri S B Chakraborthy, Sr. Dr, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : December 02, 2025 Date Of Pronouncing The Order : December 12, 2025 Order Per Pradip Kumar Choubey:

Section 131Section 133ASection 139Section 142(1)Section 143(2)Section 143(3)Section 250Section 68Section 69C

find that during the F.Y-2017-18, the assessee owned two luxury cars of make Mercedes Benz and Hyundai Creta for which opening WDV of Rs.46,53,188/- and 13,75,376/- totalling to Rs.60,28,564/-. We further find that the Assessing Officer disallowed 30% of the total expenses relating

Chiranjilal Tea Company Pvt. Ltd., Jalpaiguri vs. D.C.I.T., Circle - 1(1), Jalpaiguri

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

ITA 2043/KOL/2025[2015-2016]Status: DisposedITAT Kolkata10 Dec 2025AY 2015-2016

Bench: Shri Rajesh Kumar (Accountant Member), Shri Pradip Kumar Choubey (Judicial Member)

Section 250

addition of Rs.72,97,419/- as done by the Assessing Officer on account of difference of closing WDV as on 31.03.2014 and the opening WDV as on 01.04.2014. 4. Aggrieved and dissatisfied, the assessee has come in appeal before us. The ld. AR submitted that the ld. CIT(A) while ... disallowance was done without considering the reconciliation statement submitted in this regard. The appellant has explained that the reason for the variance between the opening WDV of current year and closing WDV of preceding year in schedule DPM was on account of erroneous computation by its accountant

M/S Gera Developments Pvt. Ltd, Pune vs. PCIT (Central), Pune

In the result, the appeal filed by the assessee is dismissed

ITA 1053/PUN/2024[2020-21]Status: DisposedITAT Pune09 Dec 2025AY 2020-21

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Hari KrishanFor Respondent: Shri Amol Khairnar

Section 143(2)Section 143(3)Section 263

Income-tax Act is invalid and unsustainable in law, as it has been passed on the basis of the fact/premise that the opening WDV of the Block of intangible asset (goodwill) has been acquired/generated as a result of 3 M/s Gera Developments Pvt. Ltd. amalgamation of M/s Gera Realty India

Assisstant Commissioner of Income Tax, Chennai vs. Bannari Amman Sugar Limited, Coimbatore

In the result, both the appeals of the Revenue are dismissed

ITA 3361/CHNY/2024[2021]Status: DisposedITAT Chennai04 Dec 2025

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. R. Vijayarghavan &For Respondent: Mr. Shiva Srinivas CIT

Section 131Section 132Section 132(4)Section 153CSection 250

cogeneration unit, which in his view, was not eligible for higher rate of depreciation of 40% but only 15%. The AO thereafter reworked the opening WDV, addition(s) etc. of the respective blocks of assets and ITA Nos.3360 & 3361/Chny/2024 (AYs 2019-20 & 2021-22) M/s.Bannari Amman Sugars Ltd. :: 15 :: quantified

Assisstant Commissioner of Income Tax, Chennai vs. Bannari Amman Sugar Limited, Coimbatore

In the result, both the appeals of the Revenue are dismissed

ITA 3360/CHNY/2024[2019]Status: DisposedITAT Chennai04 Dec 2025

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. R. Vijayarghavan &For Respondent: Mr. Shiva Srinivas CIT

Section 131Section 132Section 132(4)Section 153CSection 250

Viacom 18, Media Pvt Ltd, Mumbai vs. PCIT-8, Mumbai

ITA 2591/MUM/2025[2019-20]Status: DisposedITAT Mumbai27 Nov 2025AY 2019-20

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Mr. Madhur Agarwal/Ms. MokshaFor Respondent: Mr. Vivek Perampurna, CIT-DR

Section 143(3)Section 144BSection 263Section 32

raised following query: “8. With respect to depreciation claimed during the year, kindly provide the following details: 1. Detail of the asset/block ii) Opening WDV iii) Addition and deletion during the year iv) Depreciation charged on assets/block T v) Detail of additional depreciation claimed, if any along with the justification ... Assessing Officer, relevant part of which is reproduced as under: “8. Depreciation claimed during the year The details with respect to fixed assets, opening WDV, additions and deletions made during the year and depreciation charged on the assets are enclosed as Annexure 3. The Company has not claimed any additional

Repal Green Power Private Limited, Hyderabad vs. DCIT Circle -3(1), Hyderabad

In the result, both the appeals of the Assessee are allowed

ITA 474/HYD/2022[2018-19]Status: DisposedITAT Hyderabad26 Nov 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.125/Hyd/2022 Assessment Year 2017-2018 Repal Green Power Private Limited, The Dcit, Circle-8(1), Vs. Hyderabad. Hyderabad – 500 081 Pan Aahcr2187F (Appellant) (Respondent) आ.अपी.सं /Ita No.474/Hyd/2022 Assessment Year 2018-2019 Repal Green Power Private Limited, The Dcit, Circle-3(1), Vs. Hyderabad. Hyderabad – 500 081 Pan Aahcr2187F (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Sri Harsh R Shah, Advocate & Ca Karan Jain राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

For Appellant: Sri Harsh R Shah, Advocate &For Respondent: MS U Mini Chandran, CIT-DR

Section 143(3)Section 234Section 234DSection 270ASection 32Section 32A

erred in not granting depreciation under Section 32(ii) and additional depreciation under Section 32(ia), without revising the opening WDV of plant and machinery on account of the amount of depreciation disallowed in the previous year. 7 ITA.Nos.125 & 474/Hyd./2022 Investment allowance under Section 32AD

Repal Green Power Private Limited, Hyderabad vs. DCIT, Circle 8(1), Hyderabad

ITA 125/HYD/2022[2017-18]Status: DisposedITAT Hyderabad26 Nov 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.125/Hyd/2022

For Appellant: Sri Harsh R Shah, Advocate &For Respondent: MS U Mini Chandran, CIT-DR

Section 143(3)Section 234Section 234DSection 270ASection 32Section 32A

erred in not granting depreciation under Section 32(ii) and additional depreciation under Section 32(ia), without revising the opening WDV of plant and machinery on account of the amount of depreciation disallowed in the previous year. Investment allowance under Section 32AD 8. On the facts and circumstances

Balachandra Builders Pvt. Ltd., Chennai vs. DCIT, Corp. Circle-1(2), Chennai

In the result, appeal of the assessee is allowed

ITA 989/CHNY/2025[2010-11]Status: DisposedITAT Chennai21 Oct 2025AY 2010-11

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 989/Chny/2025 िनधा"रण वष"/Assessment Year : 2010-11 V. Balchandra Builders Private Limited, Deputy Commissioner Of No.10 Venkataratnam Nagar, Adyar, Income Tax, Chennai- 600 020. Corporate Circle 1(2), Chennai. [Pan: Aaacb6727A] (अपीलाथ"/Appellant) (""यथ"/Respondent) : अपीलाथ" क" ओर से/ Appellant By Mr.N.Arjun Raj, Advocate, : ""यथ" क" ओर से /Respondent By Ms.R.Anitha, Addl.Cit : सुनवाई क" तार"ख/Date Of Hearing 28.07.2025 : घोषणा क" तार"ख /Date Of Pronouncement 21.10.2025

Section 143(2)Section 143(3)Section 147Section 148Section 80I

seen from the Depreciation statement for the AY 2010-11 that as sum of Rs. 12,45,16,958 / is shown as opening WDV, which includes Rs. 7,60,68,070 /- as agricultural land. However, it is seen from the ITMR for the A.Y 2009-10, the closing WDV shown

JCIT(OSD), CC-1, Lko, Lucknow vs. Acp Tollways Private Limited, Lucknow

In the result, the appeal filed by Revenue is dismissed and the Cross

ITA 131/LKW/2024[2021-22]Status: DisposedITAT Lucknow17 Oct 2025AY 2021-22

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(2)Section 32

nature but has allowed depreciation by treating it as an intangible asset. In the impugned assessment year, the assessee has claimed depreciation on the opening WDV only. As far as the nature and character of the expenditure, whether capital or revenue, has attained finality in the preceding assessment years wherein

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)

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 of the conversion of Allscripts India Pvt. Ltd. into a Limited ... already been added back in the computation of income for A.Y. 2017-18 and provided reconciliations to demonstrate that the opening WDV for A.Y. 2018-19 was correct as per law. After examining the submissions and reconciliations, the explanation of the assessee was found satisfactory and no adjustment was made