Held, allowing the appeal the Court held that the fifth proviso to section 32(1) pertained to the aggregate deduction allowable to the predecessor and successor in the year immediately following a succession, amalgamation or demerger, and could regulate affairs only for the assessment year directly succeeding such event. Since the scheme came into effect in the financial year 2013-2014, the proviso was relevant only for the assessment year 2014-2015 and had no application to the assessment years 2015-2016 and 2016-2017. That although it was contended that section 43(6)(c) and the appended Explanations governed the manner of computing the written-down value, the Tribunal had not examined the matter from that perspective and had based its decision only on the fifth proviso to section 32(1), which was not applicable. The matter was  remanded to the Tribunal for fresh consideration in accordance with law.(AY.2015-16, 2016-17)