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“ready for use”

DepreciationSection 32Section 3294 judgments

The decision most relied on for ready for use is Capital Bus Service Pvt. Ltd. v. CIT (123 ITR 404), cited in 91 judgments on BharatTax.

Leading authorities on ready for use

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.

CIT v. Refrigeration & Allied Industries Ltd.
247 ITR 12 · 2001 · High Court
50
citing judgments

An asset, once installed and kept in an operational condition for business use, is eligible for depreciation even if it is not actively used during the entire previous year due to external business reasons.

Whittle Anderson Ltd. v. CIT
79 ITR 613 · 1971 · High Court
36
citing judgments

An asset kept ready for use in a business is considered to be 'used' for the purpose of business, entitling the assessee to depreciation, even if it is not actively operated or was not used in prior years. Passive usage of an asset also qualifies for depreciation.

Dineshkumar Gulabchand Agrawal v. CIT
267 ITR 768 · 2004 · High Court
30
citing judgments

The asset must be actually used for the purpose of business to be eligible for depreciation, not merely ready for use.

CIT v. Viswanath Bhaskar Sathe
5 ITR 621 · 1937 · High Court
26
citing judgments

Depreciation allowance can be claimed for an asset even if it is not actively used in the business, as the term 'used' encompasses both passive and active user. Machinery kept idle may still depreciate.

CIT v. Geo Tech Construction Corporation
244 ITR 452 · 2000 · High Court
23
citing judgments

An asset can be considered 'used' for business purposes, entitling the assessee to depreciation, even if it was only passively used or kept ready for use. The definition of 'used' for depreciation purposes is broader than actual physical employment.

CIT v. Yamaha Motor India Pvt. Ltd.
328 ITR 297 · 2009 · High Court
19
citing judgments

An asset is considered 'used for the purpose of business' under Section 32 of the Income Tax Act if it is kept ready for use, even if not actually put to use during the relevant period. This interpretation allows for depreciation claims in such scenarios.

CIT v. Larsen & Toubro Ltd.
89 Taxmann.com 186 · 2018 · High Court
17
citing judgments

Depreciation is allowable on assets that are kept "ready for use," not just those in "actual use." This interpretation applies to the term "use" in Section 32 of the Income Tax Act.

Judgments citing ready for use

Kings Infra Ventures Ltd, Thevara vs. Assistant Commissioner of Income Tax Circle 1 (2), Kochi

In the result, the appeal by the assessee is dismissed

ITA 25/COCH/2017[2011-2012]Status: DisposedITAT Cochin24 Apr 2023AY 2011-2012

Bench: Shri Sanjay Arora & Shri Sandeep Gosainkings Infra Ventures Ltd. Asstt. Commissioner Of A-1, 1St Floor, Atria Apartment Income Tax, Opp. Gurudwara Temple Vs. Circle - 1(2) Perumanur Road Kochi Thevara, Kochi [Pan:Aaccv3411D] (Respondent) (Appellant) Appellant By: Shri Joseph Markose, Sr. Advocate Respondent By: Smt. J.M. Jamuna Devi, Sr. D.R.

For Appellant: Shri Joseph Markose, Sr. AdvocateFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 139(1)Section 143(3)

Infra Ventures Ltd. v. Asst. CIT “6.3 The above factual finding of the CIT(A) that the asset in question was not kept ready for use condition and there was no passive use of the same for the assessment years 1999-2000 to 2009-10, has not been dispelled ... kept in a state of readiness for being used so as to qualify, assuming so, for an allowance of depreciation. The argument of ready-to-use state, which has factual and legal aspects to it, is understandable in a scenario of a temporary disruption of business, justifying keeping them

A.R.A.P Enterprises P Ltd, Chennai vs. ACIT(OSD), Ncr-1, Chennai

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

ITA 535/CHNY/2021[2015-16]Status: DisposedITAT Chennai14 Dec 2022AY 2015-16

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita No.535/Chny/2021 िनधा"रण वष" /Assessment Year: 2015-16 M/S.A.R.A.P. Enterprises Pvt. Ltd., V. The Asst. Commissioner Of New No.35-37, Old No.17-18, Income Tax (Osd), Gandhi Irwin Road, Ncr-1, Chennai. Egmore, Chennai-600 008. [Pan: Aagca 9262 R] (अपीलाथ"/Appellant) (""यथ"/Respondent) : अपीलाथ" क" ओर से/ Appellant By Mr.R.Venkatraman, Irs & Mr.R.Viswanathan, Ca ""यथ" क" ओर से /Respondent By : Mr. Ar.V.Sreenivasan, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 07.12.2022 घोषणा क" तारीख /Date Of Pronouncement : 14.12.2022

For Respondent: Mr. AR.V.Sreenivasan
Section 37(1)

ground that the assessee has put to use motor buses for less than 182 days. According to the AO, although, the buses were ready for use, but the assessee has started using buses in the business of transportation of passengers from October, 2014 onwards. Therefore, the AO opined that ... being booking charges for buses from the month of August, 2014. He further submitted that as regards ‘2’ buses, those ‘2’ buses were ready to use, but only registration has been taken in the month of October, 2014. Therefore, he argued that as per Motor Vehicles Rules, the assessee needs

Kamivisa Products, Pondicherry vs. DCIT, Pondicherry

In the result, appeals filed by the assessee are allowed

ITA 995/CHNY/2018[2012-13]Status: DisposedITAT Chennai21 Sept 2022AY 2012-13

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपीलसं./I.T.A.Nos.881 To 884 & 995/Chny/2018 ("नधा"रणवष" / Assessment Years: 2008-09 To 2011-12 & 2012-13)

Section 139(1)Section 80I

ready for next level of production. The assessee further contended that Guwahati unit has spent further amount towards making products purchased from Puducherry ready for use at next level. If you consider said cost, then purchase price paid by the assessee to its Puducherry unit and purchase price paid

M/S Kamivisa Products, Pondicherry vs. DCIT, Pondicherry

In the result, appeals filed by the assessee are allowed

ITA 884/CHNY/2018[2011-12]Status: DisposedITAT Chennai21 Sept 2022AY 2011-12

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपीलसं./I.T.A.Nos.881 To 884 & 995/Chny/2018 ("नधा"रणवष" / Assessment Years: 2008-09 To 2011-12 & 2012-13)

Section 139(1)Section 80I

ready for next level of production. The assessee further contended that Guwahati unit has spent further amount towards making products purchased from Puducherry ready for use at next level. If you consider said cost, then purchase price paid by the assessee to its Puducherry unit and purchase price paid

M/S Kamivisa Products, Pondicherry vs. DCIT, Pondicherry

In the result, appeals filed by the assessee are allowed

ITA 883/CHNY/2018[2010-11]Status: DisposedITAT Chennai21 Sept 2022AY 2010-11

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपीलसं./I.T.A.Nos.881 To 884 & 995/Chny/2018 ("नधा"रणवष" / Assessment Years: 2008-09 To 2011-12 & 2012-13)

Section 139(1)Section 80I

ready for next level of production. The assessee further contended that Guwahati unit has spent further amount towards making products purchased from Puducherry ready for use at next level. If you consider said cost, then purchase price paid by the assessee to its Puducherry unit and purchase price paid

M/S Kamivisa Products, Pondicherry vs. DCIT, Pondicherry

In the result, appeals filed by the assessee are allowed

ITA 882/CHNY/2018[2009-10]Status: DisposedITAT Chennai21 Sept 2022AY 2009-10

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपीलसं./I.T.A.Nos.881 To 884 & 995/Chny/2018 ("नधा"रणवष" / Assessment Years: 2008-09 To 2011-12 & 2012-13)

Section 139(1)Section 80I

ready for next level of production. The assessee further contended that Guwahati unit has spent further amount towards making products purchased from Puducherry ready for use at next level. If you consider said cost, then purchase price paid by the assessee to its Puducherry unit and purchase price paid

M/S Kamivisa Products, Pondicherry vs. DCIT, Pondicherry

In the result, appeals filed by the assessee are allowed

ITA 881/CHNY/2018[2008-09]Status: DisposedITAT Chennai21 Sept 2022AY 2008-09

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपीलसं./I.T.A.Nos.881 To 884 & 995/Chny/2018 ("नधा"रणवष" / Assessment Years: 2008-09 To 2011-12 & 2012-13)

Section 139(1)Section 80I

ready for next level of production. The assessee further contended that Guwahati unit has spent further amount towards making products purchased from Puducherry ready for use at next level. If you consider said cost, then purchase price paid by the assessee to its Puducherry unit and purchase price paid

M/S Well Wisher Construction Pvt Ltd., Navi Mumbai vs. DCIT Ward 18 (1), New Delhi

In the result, the appeal of the assessee in ITA

ITA 7605/MUM/2019[2010-11]Status: DisposedITAT Mumbai20 Sept 2022AY 2010-11

Bench: Shri Pradip Kumar Kedia & Shri Rahul Chaudhary

For Appellant: Shri Khushiram JadhwaniFor Respondent: Shri Tushar Mohite, Sr.D.R

I.T.A. No.7605 & 7606/Mum/2019 observed that where the assets owned by the assessee were idle but were kept ready for use at any time and the contingency from use could also fall within the definition of word ‘used’ for the purposes of eligibility of depreciation notwithstanding non-generation of positive income

Pr. CIT Circle-2, Mumbai vs. Bharat Prtroleum Corporation Ltd., Mumbai

In the result, the appeal of the assessee is partly allowed

ITA 1601/MUM/2020[2016-17]Status: DisposedITAT Mumbai05 Sept 2022AY 2016-17

Bench: Shri Pramod Kumar, Vp & Shri Aby T. Varkey, Jm आयकर अपील सं/ I.T.A. No.1601/Mum/2020 (निर्धारण वर्ा / Assessment Year: 2016-17) Bharat Petroleum बिधम/ Pcit, Circle-2 Corporation Ltd. Room No.344, Aayakar Vs. Taxation Section, Bhavan, M. K. Road, 4Th Floor, Bharat Bhavan 1, Mumbai-400020. 4 & 6 Currimbhoy Road, Ballard Estate, Mumbai- 400001. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaacb2902M (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Jehangir D. Mistry Revenue By: Dr. Mahesh Akhade (Dr) सुनवाई की तारीख / Date Of Hearing: 28/06/2022 घोषणा की तारीख /Date Of Pronouncement: 05/09/2022 आदेश / O R D E R Per Aby T. Varkey, Jm: This Appeal Has Been Preferred By The Assessee Against The Order Of The Ld. Principal Commissioner Of Income Tax-02 [Hereinafter Referred To As The “Pcit”], Mumbai Dated 21.02.2020 For Assessment Year [Hereinafter Referred To As “Ay”] 2016-17 Passed Under Section 263 Of The Income Tax Act, 1961 [Hereinafter Referred To As “The Act”].

For Appellant: Shri Jehangir D. MistryFor Respondent: Dr. Mahesh Akhade (DR)
Section 10(34)Section 142(1)Section 143(3)Section 2Section 263Section 32A

defined in the section or the Act. The Oxford Dictionary meaning of the word ‘install’ is place or fix equipment in position, ready to use. The Tribunal in the case of Tejbali Singh Transport Co. vs. ITO, 27 TTJ (Jab) 405 explained the expression installed with reference to section ... section, the Tribunal rejected the stand of Revenue that expression ‘installed’ means permanently fixed and held, “Installation” simply means making a machine ready for use and nothing more. The Tribunal allowed assessee’s claim holding that the pay loader machine fell under clause III (D)(8) of Appendix

ACIT Cir 2(2)(1), Mumbai vs. L & T Ltd ( Datar Switch Gear Ltd Merged ), Mumbai

In the result, the appeal filed by the revenue is allowed and the cross objection filed by the assessee is treated as allowed for statistical purposes

ITA 3806/MUM/2016[2004-05]Status: DisposedITAT Mumbai03 Aug 2022AY 2004-05
Section 143(3)

that the assets should be actually used for the purposes of business in order to claim depreciation. Mere fact that the asset is ready for use is not sufficient. In support of this proposition, the Ld D.R placed his reliance on the decision rendered by Hon’ble Bombay High Court ... disputes between the assessee and MSEB, the remaining 14,206 units could not be given to MSEB on lease, even though they were ready for use. Since there was breach of contract by MSEB, the assessee referred the matter to arbitration and the arbitration tribunal has allowed compensation

Jt. CIT (OSD), CC-7(2), Mumbai vs. M/S. Andhra Expressway Ltd, Mumbai

In the result, both the appeals filed by the revenue stands dismissed

ITA 1588/MUM/2021[2014-15]Status: DisposedITAT Mumbai24 Jun 2022AY 2014-15

Bench: Shri G. S. Pannu & Shri Amit Shukla, Jm आयकरअपीलसं./ I.T.A. No. 1588/Mum/2021 (ननधधारणवर्ा / Assessment Year: 2014-15) & आयकरअपीलसं./ I.T.A. No. 1589/Mum/2021 (ननधधारणवर्ा / Assessment Year: 2013-14) Jcit (Osd), Cc-7(2), M/S Andhra Expressway Ltd. R. No. 655, Aayakar बनाम/ Ground Floor, Gammon Bhavan, M. K. Road, House, Veer Savarkar Vs. Mumbai-400020 Marg, Prabhadevi, Mumbai-400 025 स्थधयीलेखधसं./जीआइआरसं./ Pan No. Aadca3577E (अपीलधथी/Appellant) (प्रत्यथी / Respondent) : अपीलधथीकीओरसे/ Appellant By : Smt. Shailja Rai, Ld. Dr प्रत्यथीकीओरसे/Respondent By Shri Rakesh Joshi, Ld. Ar : सुनवधईकीतधरीख/ : 01.06.2022 Date Of Hearing घोर्णधकीतधरीख / : 24.06.2022 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla: The Aforesaid Appeals Have Been Filed By The Revenue Against The Separate Impugned Order Of Even Date 29.06.2021, Passed By 2

For Appellant: Smt. Shailja Rai, Ld. DR
Section 143(3)Section 32Section 32(1)(ii)Section 80I

concession period of 11 years and 7 months, the assessee can start operating and collecting toll charges only when the project facility is ready for use. Therefore, until the project is completed and ready for use by vehicles or persons assessee cannot collect toll charges for user of the project

Sagar Damoh Toll Roads Limited, Mumbai vs. Asst CIT 8(1)(2), Mumbai

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

ITA 3147/MUM/2019[2013-14]Status: DisposedITAT Mumbai28 Apr 2022AY 2013-14

Bench: Shri Prashant Maharishi & Shri Pavan Kumar Gadalesagar Damoh Toll Vs. Acit, Circle – 8(1)(2) Roads Ltd Room No. 651, 6Th 513A, 5Th Floor, Floor, Aayakar Kohinoor City, Kirol Bhavan, Mk Road, Road, Off Lbs Marg, Mumbai – 400020. Kurla, Mumbai – 400070 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aacce2160Q Appellant .. Respondent Appellant By : Shri. K. Shivaram.Ar Respondent By : Shri Ajay K. Shrivastava.Dr Date Of Hearing 22.03.2022 Date Of Pronouncement 29.03.2022 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Assessee Has Filed The Appeal Against The Order Of The Commissioner Of Income Tax (Appeals)-14, Mumbai Passed 143(3) & 250 Of The Act. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri. K. Shivaram.ARFor Respondent: Shri Ajay K. Shrivastava.DR
Section 143(1)Section 143(2)Section 250Section 32(1)(ii)

concession period of 11 years and 7 months, the assessee can start operating and collecting toll charges only when the project facility is ready for use. Therefore, until the project is completed and ready for use by vehicles or persons assessee cannot collect toll charges for user of the project

Bharat Prtroleum Corporation Ltd., Mumbai vs. Pr. CIT Circle-2, Mumbai

In the result, appeal of the assessee is allowed for parity of reasons

ITA 1602/MUM/2020[2015-16]Status: DisposedITAT Mumbai23 Feb 2022AY 2015-16

Bench: Shri Vikas Awasthy & Shri M. Balaganeshआअसं. 1602/मुं/2020 ("न. व. 2015-16) आअसं. 1600/मुं/2020 ("न.व. 2017-18) Bharat Petroleum Corporation Ltd. Taxation Section, 4Th Floor, Bharat Bhavan, 4 & 6 Currimbhoy Road, Ballard Estate, Mumbai 400 001 Pan: Aaacb-2902-M ...... अपीलाथ" /Appellant बनाम Vs. The Principal Commissioner Of Income Tax, Circle -2, Room No.344, Aaykar Bhavan, M.K.Road, Mumbai 400 020 ..... ""तवाद"/Respondent अपीलाथ" "वारा/ Appellant By : Shri Jehangir D. Mistry, Sr. Advocate ""तवाद" "वारा/Respondent By : S/Shri Rahul Raman & B.K. Bagchi सुनवाई क" "त"थ/ Date Of Hearing : 26/11/2021 घोषणा क" "त"थ/ Date Of Pronouncement : 23/02/2022 आदेश/ Order

For Appellant: Shri Jehangir D. Mistry, Sr. AdvocateFor Respondent: S/Shri Rahul Raman & B.K. Bagchi
Section 10(34)Section 236Section 263Section 32A

defined in the section or the Act. The Oxford Dictionary meaning of the word ‘install’ is place or fix equipment in position, ready to use. The Tribunal in the case of Tejbali Singh Transport Co. vs. ITO, 27 TTJ (Jab) 405 explained the expression installed with reference to section ... section, the Tribunal rejected the stand of Revenue that expression ‘installed’ means permanently fixed and held, “Installation” simply means making a machine ready for use and nothing more. The Tribunal allowed assessee’s claim holding that the pay 12 ITA NO.1600/MUM/2020 (A.Y.2017-18) loader machine fell under clause

Bharat Petroleum Corporation Ltd., Mumbai vs. Pr. CIT, Circlr-2, Mumbai

In the result, appeal of the assessee is allowed for parity of reasons

ITA 1600/MUM/2020[2017-18]Status: DisposedITAT Mumbai23 Feb 2022AY 2017-18

Bench: Shri Vikas Awasthy & Shri M. Balaganeshआअसं. 1602/मुं/2020 ("न. व. 2015-16) आअसं. 1600/मुं/2020 ("न.व. 2017-18) Bharat Petroleum Corporation Ltd. Taxation Section, 4Th Floor, Bharat Bhavan, 4 & 6 Currimbhoy Road, Ballard Estate, Mumbai 400 001 Pan: Aaacb-2902-M ...... अपीलाथ" /Appellant बनाम Vs. The Principal Commissioner Of Income Tax, Circle -2, Room No.344, Aaykar Bhavan, M.K.Road, Mumbai 400 020 ..... ""तवाद"/Respondent अपीलाथ" "वारा/ Appellant By : Shri Jehangir D. Mistry, Sr. Advocate ""तवाद" "वारा/Respondent By : S/Shri Rahul Raman & B.K. Bagchi सुनवाई क" "त"थ/ Date Of Hearing : 26/11/2021 घोषणा क" "त"थ/ Date Of Pronouncement : 23/02/2022 आदेश/ Order

For Appellant: Shri Jehangir D. Mistry, Sr. AdvocateFor Respondent: S/Shri Rahul Raman & B.K. Bagchi
Section 10(34)Section 236Section 263Section 32A

defined in the section or the Act. The Oxford Dictionary meaning of the word ‘install’ is place or fix equipment in position, ready to use. The Tribunal in the case of Tejbali Singh Transport Co. vs. ITO, 27 TTJ (Jab) 405 explained the expression installed with reference to section ... section, the Tribunal rejected the stand of Revenue that expression ‘installed’ means permanently fixed and held, “Installation” simply means making a machine ready for use and nothing more. The Tribunal allowed assessee’s claim holding that the pay 12 ITA NO.1600/MUM/2020 (A.Y.2017-18) loader machine fell under clause

M/S. Tejas Networks Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Ltu, Circle-1, Bengaluru

In the result, the appeals filed by the revenue in IT(TP)A No

ITA 582/BANG/2021[2010-11]Status: DisposedITAT Bangalore09 Feb 2022AY 2010-11

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

For Appellant: Shri Jairam Raipura, D.RFor Respondent: Shri Annamalli & Shri Narendra Sharma, A.Rs
Section 154

which was capitalised in the books of accounts under the head fixed assets on the contention that the expenditure represents know-how / technology ready for use contributing to increase in revenue and giving enduring benefit. 3.9 The learned AO thereby erred in disallowing Rs. 53,72,75,727 under section

M/S Tejats Networks Limited, Bangalore vs. Principal Commissioner of Income Tax Central, Bangalore

In the result, the appeals filed by the revenue in IT(TP)A No

ITA 1674/BANG/2018[2011-12]Status: DisposedITAT Bangalore09 Feb 2022AY 2011-12

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

For Appellant: Shri Jairam Raipura, D.RFor Respondent: Shri Annamalli & Shri Narendra Sharma, A.Rs
Section 154

which was capitalised in the books of accounts under the head fixed assets on the contention that the expenditure represents know-how / technology ready for use contributing to increase in revenue and giving enduring benefit. 3.9 The learned AO thereby erred in disallowing Rs. 53,72,75,727 under section

Tejas Networks Limited, Bangalore vs. DCIT, Bangalore

In the result, the appeals filed by the revenue in IT(TP)A No

ITA 694/BANG/2016[2011-12]Status: DisposedITAT Bangalore09 Feb 2022AY 2011-12

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

For Appellant: Shri Jairam Raipura, D.RFor Respondent: Shri Annamalli & Shri Narendra Sharma, A.Rs
Section 154

which was capitalised in the books of accounts under the head fixed assets on the contention that the expenditure represents know-how / technology ready for use contributing to increase in revenue and giving enduring benefit. 3.9 The learned AO thereby erred in disallowing Rs. 53,72,75,727 under section

DCIT, Bangalore vs. M/S Tejas Networks Limited, Bangalore

In the result, the appeals filed by the revenue in IT(TP)A No

ITA 621/BANG/2016[2011-12]Status: DisposedITAT Bangalore09 Feb 2022AY 2011-12

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

For Appellant: Shri Jairam Raipura, D.RFor Respondent: Shri Annamalli & Shri Narendra Sharma, A.Rs
Section 154

which was capitalised in the books of accounts under the head fixed assets on the contention that the expenditure represents know-how / technology ready for use contributing to increase in revenue and giving enduring benefit. 3.9 The learned AO thereby erred in disallowing Rs. 53,72,75,727 under section

Tejas Networks Limited, Bangalore vs. Asst.C.I.T., Bangalore

In the result, the appeals filed by the revenue in IT(TP)A No

ITA 468/BANG/2015[2010-11]Status: DisposedITAT Bangalore09 Feb 2022AY 2010-11

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

For Appellant: Shri Jairam Raipura, D.RFor Respondent: Shri Annamalli & Shri Narendra Sharma, A.Rs
Section 154

which was capitalised in the books of accounts under the head fixed assets on the contention that the expenditure represents know-how / technology ready for use contributing to increase in revenue and giving enduring benefit. 3.9 The learned AO thereby erred in disallowing Rs. 53,72,75,727 under section

Asst.C.I.T., Bangalore vs. M/S Tejas Networks Limited, Bangalore

In the result, the appeals filed by the revenue in IT(TP)A No

ITA 296/BANG/2015[2010-11]Status: DisposedITAT Bangalore09 Feb 2022AY 2010-11

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

For Appellant: Shri Jairam Raipura, D.RFor Respondent: Shri Annamalli & Shri Narendra Sharma, A.Rs
Section 154

which was capitalised in the books of accounts under the head fixed assets on the contention that the expenditure represents know-how / technology ready for use contributing to increase in revenue and giving enduring benefit. 3.9 The learned AO thereby erred in disallowing Rs. 53,72,75,727 under section