The assessee carried on its operations till 1986. From the assessment year 1986-87, the manufacturing activities of the assessee came to a stop for various reasons. The assessee then commenced operations only in the year 2010. Till 1995-96, the assessee was claiming depreciation; both carried forward and that arising in the respective years. The claim was rejected by the AO. On appeal the Tribunal allowed the claim on the ground of passive use of the assets, meaning the assessee having had the intention to revive the industry and kept the machinery ready for use for the purpose of commencement of manufacturing activities. On appeal by the revenue the Court held that assessee could not be allowed to claim depreciation on assets for all these years when they were not put to use and when such claim did not arise under S.  32(1), then there was no question of any carry forward of depreciation for such period when assets of assessee were not put to use during relevant year. (Arising  from  Punalur Paper Mills Ltd. v ITO  (2009) 29 SOT 449 (Cochin) (Trib)  (ITA Nos. 1378 to 1423 of 2019 dt. 7 -02 -2019)    (AY. 1996 -97 to 2002 -03)