Dismissing the appeal of revenue the Court held that deduction of depreciation from gross receipts of income estimated @ 12.5 per cent on main contractual receipts is a debatable question of law and fact. Order of Tribunal is affirmed. Followed T.S. Balaram, ITO v. Volkart Brothers & Ors. (1971) 82 ITR 50 / 2 SCC 526 (AY. 2008-09)
PCIT v. Engineers Works (2021) 323 CTR 485 (AP)(HC)
S. 154 : Rectification of mistake-Depreciation-Contractor-Income estimated at 12.5 % of contractual receipts-Debatable-Rectification was held to be not justified. [S. 32(1)(ii)]