Pawan Hans Helicopters Ltd. v. DCIT (2021) 212 TTJ 1010 / 204 DTR 347 / (2022) 192 ITD 142 (Delhi)(Trib.)

S. 32 : Depreciation-Westland Helicopters-Block of asset User of asset-The concept of user of assets has to apply upon block of asset as a whole instead individual assets-Denial of depreciation is held to be not valid. [S. 2(11)]

Held that when a particular asset is part of block of assets even when that particular asset is not used in the relevant assessment year, the depreciation is allowable. Followed Sony India (P) Ltd. v. CIT (2017) 88 taxmann.com 580 (Delhi)(HC), CIT v. Oswal Agro Mills Ltd. (2011) 341 ITR 467 (Delhi)(HC). (AY. 1995-96)