Suzuki Motor Gujarat (P.) Ltd. v. PCIT (2025) 212 ITD 49 (Ahd) (Trib.)

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Additional depreciation-At rate of 10 per cent on ‘plant and machinery’ put to use for a period of less than 180 days during preceding year-No error-Revision order is set aside. [S. 32(1)(ii), 43(6)]

During preceding assessment year 2017-18, assessee had claimed additional depreciation at rate of 10 per cent on plant and machinery put to use for a period of less than 180 days.  Balance additional depreciation was carried forward to be claimed in assessment year 2018-19 as per third proviso to section 32(1)(ii).  For year under consideration, assessee claimed aggregate depreciation which included additional depreciation pertaining to assets put to use for less than 180 days in preceding assessment year.  Principal Commissioner revised assessment order on ground that assessee had claimed excess normal depreciation for year under consideration. On appeal the Tribunal held that there was no error in depreciation claimed by assessee and, hence revision order is set aside. (AY. 2018-19)

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