The Tribunal held that the assets have been transferred from one government to another. There is no claim of the depreciation twice by both the Governments. The demerger led to division of assets in a fixed ratio and the same was duly accounted for, by both the entities as per the written down value (WDV) as on that date. The depreciation cannot be a forgone benefit owing to de-merger, which in this case is the result of state reorganization. (AY. 2012-13)