The Tribunal held that there was no rational and justifiable basis for the Commissioner (Appeals) to disturb the basis of allowing the depreciation on the written down value basis instead of the straight line method basis as claimed by and allowed to the assessee over the years where there was no change in the facts and circumstances of the case. The Assessing Officer was directed to allow the depreciation on straight line method. (AY. 2017-18)
SEl Manufacturing Co. Ltd v. Dy.CIT (2022)97 ITR 79 (SN) (Chd)(Trib)
S. 32: Depreciation-Generation and distribution of power-Multiple units of Captive Power Plant-Adopting Straight Line Method-Accepted in previous and subsequent years-No change in facts-Directed to allow depreciation on Straight Line Method. [S. 32(1)(i)]